Mapping risk assessment and management status of recycled food contact materials in Europe - risk analysis in a circular economy

Background
The European Union's transition toward a circular economy introduces new challenges for the safety of food contact materials (FCM), particularly those made from recycled or reused substances. Recycling processes often increase the presence of non-intentionally added substances due to faulty sorting, material degradation, and other factors, rendering the exact chemical composition of recycled materials unpredictable. Furthermore, many substances currently used in FCM remain unassessed for health risks, complicating both hazard identification and exposure estimation.

Scope and approach
This study reviews potential challenges within the risk analysis of recycled FCM and examines the current state of risk assessment and risk management for key compounds of concern in recycled FCM - Bisphenol A (BPA), Bisphenol S (BPS), and mineral oil saturated and aromatic hydrocarbons (MOSH/MOAH). Using a survey-based tool developed for competent authorities yielded data that were transferred into geographical maps showing the current state in different European countries.

Key findings and conclusions
The maps highlight large differences across European countries in terms of both risk assessment and management, with some nations having risk assessed contaminants and actively monitoring and regulating, while others have yet to initiate these processes. The fragmented legal landscape, primarily shaped by national legislation, further impedes harmonised risk management. Therefore, the study proposes the use of geographical maps to integrate risk assessment data with national regulatory information, thereby facilitating information exchange and supporting the ‘one substance, one assessment’ approach.