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Australian Guidance on Categorizing food contact materials


FCM risk management chemical inventory

The Australian Department of Health (DOH) announced guidance for manufacturers and importers of chemicals that have an end-use in food-contact articles. The guidance shares six steps to categorize food-contact chemicals as “exempted”, “reported”, or “assessed”, while chemicals that are on their inventory are categorized as “listed”.

The guidance provides examples of food-contact articles such as food wrapping, food containers, coatings on the inside of food cans, and coatings on the insides of water storage tanks. However, chemicals used in cardboard, glass, or metal packaging that has no direct contact with food are not included in this scheme. Moreover, it classifies industrial chemicals introduced for an end-use in food-contact materials as a ‘specified class of introduction’ due to their potentials of migrating to food.

DOH shares the record-keeping obligations for exempted or reported introductions of a chemical for use in food-contact materials. The aim of the record-keeping, according to the DOH, is to ensure chemicals do not pose human health and environment hazard characteristics. The guidance requires to keep the following records in case the new substances have not been internationally evaluated for human health.

  • Data approved by other national authorities for the use of the substance in food contact articles, if available
  • Data on the possibility of the substance migrating to food