Compliance work for polyolefins in food contact: Results of an official control campaign
Passing from local converters backwards through the supply chain, nine major producers of polyolefin granulates were asked to supply the declaration of compliance (DoC) and supporting documentation (SD) underpinning the safety of the substances potentially migrating into foods, as legally required in Europe. Within half a year from the request, DoCs were delivered by the converters and the granulate producers, but no SD. Only two producers provided very limited information in addition to their DoC. Some producers refused responsibility in their DoC (general disclaimer), which implies that the customers should have done the complete compliance work – but none of them did. Virtually no data was obtained on substances used other than the specifically regulated monomers and additives, and none about reaction products (including oligomeric material) and impurities. Comprehensive two-dimensional gas chromatography (GC×GC) was used to generate semiquantitative pictures of the low molecular constituents in the granulates, visualizing the extent of compliance work expected. In conclusion, there is a broad gap between the legal requirements and reality that ought to be eliminated. It does not seem technically impossible.