Safeguard - CTT-FCM-S19006 (E) Food Contact Materials Recall Notification—2019 First Half Report of RASFF

In the first half of 2019，Rapid Alert System for Food and Feed (RASFF) issued 76 recalls of food contact materials (FCM) worldwide.  

1.Analysis of Substance/Hazard of the Recalls (See Figure 1)

No.1: Migration of formaldehyde

The migration of formaldehyde recalls mainly from Melamine and Bamboo fiber. These materials have been widely used in tableware, especially for children's.  However, the recalled rate is as high as 35.5%.

No.2: Migration of melamine

The high risk materials is the same with formaldehyde and the recalled rate is as high as 23.7%.

No.3: Migration of primary aromatic amines (PAA)

PAA may arise in materials intended for food contact as a result of the presence of impurities or breakdown products. PAA is of high recall rate in Polyamide/Nylon materials and products. Paper napkins are also recalled of PAA.

Other Substance / Hazard

Pay attention on the organoleptic and physical characteristics which are easy to be ignored. It is the first time to recall migration of cyclic oligomers from polyamide casings. Nickel, chromium and manganese are still the key recalled  substances in stainless steel materials from Italian.  

2.Analysis of Notification Country (See Figure 2)

The main notification country is Italy, Spain and Germany with the recall rate of18.4%, 11.8%, 11.8% respectively

3.Country of Origin

▌In total of 76 recalls, 64 cases come from China, the proportion is as high as 84% (see Figure 3).

▌Across all the recalls notified by Italy, products from China accounted for the majority at 85.7% of the total. The recalled products are mainly kitchenware/tableware of plastic (especially melamine & nylon)/metal materials.

▌Similarly, among the top three notification countries, the recalls notified by Spain and Germany, products from China also accounted for the majority at 77.8% of the total respectively.

4.Analysis of Recalled Materials

▌Plastics, bamboo and metal are the Top 3 materials with the highest recall rate.

▌The rate of plastics is almost close to half of the total number of recalls.

▌There is no mandatory regulation for bamboo products at present, but its risk is similar to that of plastics, which also attracts much attention.

5.Analysis of Recalled Substances/Hazards from Different Notification Country(See Table 1)

Some countries have high recall rates for certain substances, which require special attention when exporting products to them.

6.Compliance of Recalled Products (See Table 2)

In 2011, Europe Commission have setspecific Regulation (EU) No 284/2011 for the import of polyamide and melamine plastic kitchenware originating in or consigned from the China (include HongKong). Customs will carry out documentary checks on all shipments within 2 working days upon arrival and will perform identification and physical checks, including lab analysis of 10% of shipments. The Regulation requires that products must meet certain specific migration limit requirements.

Stainless steel materials are widely usedas food contact materials around the world owing to its good properties of heat resistance, anticorrosion, mechanical processing and smooth appearance. Italy directs more concern on such materials with most frequent market enforcement among the EU countries.

Compliance of other substances are also shown in table 2.

Summary

▌64 recalls come from China, the proportion is as high as 84%.

▌The main notification country is Italy, Spain and Germany.

▌The top 3 reasons for recalls are the migration of formaldehyde, melamine and PAA.

Seeing from the past several years, EU countries validated many notifications on FCMs on the RASFF Portal, among which more than 80% recalls were from China.  CTT advises companies to assess the compliance of FCM, according to the latest standards to facilitate the entry of EU market.