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HEAL submission on BPA Roadmap and food packing

The EU Commission recently published a roadmap proposing options for increasing controls on the use of bisphenol A (BPA) in food contact materials. HEAL, already concerned for many years about the health impact of BPA submitted a response to the EU consultation on the roadmap.

BPA is a chemical used in the production of polycarbonate plastics and the linings of aluminium food and drink cans. It is widely considered to have endocrine disrupting effects but has not yet been officially recognised as such in the European system.

HEAL welcomes the fact that the EU Commission (DG SANTE) is examining BPA in food contact materials (FCM) with its roadmap. Action on BPA in FCM is urgently needed and long overdue. HEAL has extensive concerns about the impact on public health from other hazardous and unknown chemicals in FCM which have individual and combination effects. In addition, some of these chemicals may act in an additive manner with BPA, so their presence in FCM should be quickly addressed. HEAL does not think that proceeding with ‘Mutual Recognition’ between national rules, instead of EU legislative action, will effectively reduce the public’s exposures to harmful FCM chemicals.

Regarding the BPA roadmap, HEAL’s submission to the consultation also includes the following points:

  • Consultation process: The process for this roadmap is not clearly laid out, and full transparency is lacking. Despite significant implications for the health of European citizens, this consultation is not listed on the DG SANTE FCM consultation webpage. The roadmap content does not show that prior inputs from environmental, health and consumer organisations were sought or received. Another neglected stakeholder group are trade unions whose workers are exposed during the manufacture of food contact materials. There is thus a resulting imbalance in analysis put forward by the roadmap and HEAL believes that this should be addressed.
  • Roadmap content: The roadmap suffers from a lack of attention to chemical exposure issues, or to health concerns which remain despite EFSA’s opinion. A simple analysis shows consumers are mentioned 11 times, whereas industry is mentioned over 40 times.

HEAL believes a ban at EU level on all bisphenols with suspected hormone disrupting properties for FCM is necessary. Given the ongoing criticism of the EFSA opinion from national bodies and scientists, HEAL believes that laying all the EU BPA FCM risk management eggs in the EFSA no/low concern basket is a poor policy choice.

HEAL makes further detailed comments in its written submission to the Parts on Context and Objectives; Option Mapping and Assessment; and Data collection and Better Regulation. Again any solid discussion of public health interests or concerns are missing. Given the prominence of the discussion about the concerns and interests of industry, and lack of mention or discussion about public health concerns from BPA throughout the whole document, it is clear that the option (5) – a ban on BPA in all food contact materials at EU level - which requires the closest attention for its enormous potential health benefits has not been properly investigated, which prejudices its fair and balanced consideration.

You can read HEAL’s submission here

Further information:

Last updated on 26 January 2016

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The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union (EU). We demonstrate how policy changes can help protect health and enhance people’s quality of life. Read more »

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HEAL has over 70 member organisations, representing health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health institutes. Members include international and Europe-wide organisations, as well as national and local groups. Read more »

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