In most cases, an adhesive is not considered as a plastic material. Consequently, the Regulation (EU) No. 10/2011 does not apply. The Union List of Authorized Substances is very helpful for the evaluation of constituents, but it is not complete. Standardized test methods for migration testing according to the Regulation (EU) No. 10/2011 aren’t applicable either in many cases.
The functionality of an adhesive as a component of food packaging and also its formulation is frequently not comparable to a plastic material. A food contact status declaration according to the Plastics Regulation is consequently only possible to a limited extent.
The Regulation (EC) No. 1935/2004 had provided for the possibility to issue an individual measure for adhesives in contact with food. However, so far there is no harmonized legislation for adhesives on the European level.
For a conformity statement on the use of adhesive in food packaging, it is therefore necessary to apply analysis and assessment systems which facilitate a risk assessment of the influence on the individual food types.