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Product safety

When packaging a product or food stuff, there are several important aspects pertaining to product and food safety to keep in mind. For example, the Commodities Act outlines the requirements that food and other products have to meet. This concerns the safety of the product for consumers and the producer’s responsibilities in this regard. One example is the interaction that may occur between the product and its packaging, which may result in substances migrating to the product from or via the packaging. Legal limits have been set for this migration. There is also a list of approved substances. You can read more about this under “More information.”

When making packaging materials more sustainable by means of recycling, the rule regarding product and food safety is “what goes in has to come out.” Packaging materials are collected, sorted, and recycled after use. The substances that are in or on the packaging have to be taken out again during the recycling process. In some cases, this concerns substances used in for example inks and fillers for materials, such as mineral oils. These can be harmful to people’s health and should not come into contact with food products after recycling.

This is usually not a problem for metal and glass because of the high processing temperatures (more than 1,400° C) which incinerate any inks and adhesives. Furthermore, glass is inert, which means that harmful substances cannot migrate into the material.

However, paper and cardboard are not heated during recycling. Instead, the fibres are de-inked where possible to reduce the quantities of substances present in the material. That this is a difficult process is evident from the fact that mineral oils are found in products packaged in recycled paper and cardboard.

If you wish to use recycled material for the production of plastic packaging materials, there are several requirements you have to meet in addition to the migration limits that apply to all materials that come into direct contact with food.


The first of these requirements is the entry requirement: 95% of the recycled plastic must have been “food approved” during the previous part of its lifecycle. In practice, this means that 95% of the packaging materials that go into the recycling process must have already been used as packaging for food products. That is often already the case for PET packaging materials. For example, most PET bottles are currently used for the production of food packaging. For returnable bottles, this goes for all packaging materials. When using PET packaging materials that are separated from household waste, it must be taken into account that more and more PET packaging materials are used for non-food applications, for example soap products.

The entry requirement is more difficult for PE and PP packaging materials, because many of these materials are used for both food and non-food products. This makes it hard to guarantee that 95% of the recycled material comes from food packaging. As a result, the applicability of recycled PE and PP is still limited to non-food uses.

Once the entry requirement has been met, a second step has to be taken: the approval of the process. The recycling process applied must produce food-safe material. The organisation responsible for inspecting recycling processes is the European Food Safety Authority (EFSA). After being approved, the process can be used to produce packaging materials for food products.

More information

Food safety requirements

Businesses that produce food products must ensure these products are safe. Consumers should not become ill after consuming their products. The national government inspects whether corporations have drawn up a food safety plan and act in accordance with food preparation regulations. You can read more information from the national government about food safety requirements here.

Food contact and materials

The EFSA is an agency created by the European Union. It offers independent scientific recommendations pertaining to food safety to support the EU’s legislation and policies. Information about food contact materials can also be found on the EFSA’s website. These are materials that come into direct contact with food products, for example packaging materials. The following EFSA articles provide an overview of the regulations pertaining to food contact materials and the rules regarding the use of materials made of (recycled) plastic that come into contact with food:
Read more about food contact materials.
- Read more about plastics and plastic recycling here.

Approved substances

Materials can only be used for food contact if all substances found in the material have been assessed and approved. In the Netherlands, there are positive lists for substances in plastic, paper and cardboard, coatings, rubber, metal, wood and cork, regenerated cellulose, and textile. Read for more information from the National Institute for Public Health and the Environment (RIVM) about approved substances.

Mineral oils in paper and cardboard packaging materials

There are several ways in which contaminants found in packaging materials can migrate to food products. One example is the presence of mineral oils in packaging materials made from recycled paper and cardboard. These mineral oils can also end up in food products in other ways, e.g. through the use of lubricating oil and hydraulic oils in harvesting and production machinery.
- In June of 2016, the KIDV released a factsheet on the scope and risks of the presence of mineral oils in packaging materials made from recycled paper and cardboard, including applicable regulations. You can find the “Mineral oils in paper and cardboard packaging materials” factsheet.
- Additionally, the KIDV hosted an information gathering about this topic with several guest speakers from the scientific and corporate communities. You can read the report of the gathering and the speakers’ presentations.

Bisfenol A (BPA)

BPA is used in for example food packaging made from hard plastics and in coatings. The KIDV regularly receives questions from businesses about the use of BPA. It has therefore drawn up a factsheet about the applications of BPA and the applicable regulations. You can find the factsheet “Bisphenol A (BPA) in packaging materials” here.

Ending the use of PVC in packaging materials

In the Framework Agreement for Packaging 2013-2022, the national government, the packaging industry and municipalities have drawn up agreements about reducing the environmental impact through prevention and recycling. One of these agreements concerns ending the use of PVC as a packaging material in supermarkets, unless strictly necessary.

In late 2014, the KIDV drew up a list to clarify what “unless strictly necessary” means. This list goes as follows:

- PVC as a coating in metal packaging materials;
- PVC as a liner for crown caps on so-called “twist-off” bottles for single use;
- PVC as a film to package sprout vegetables, mushrooms, dates, pre-cut vegetables, etc.;
- PVC  as a packaging material in the pharmaceutical sector for all legally registered medications, where relevant;
- PVC as a film used to package meat and meat products is not included on the “unless strictly necessary” list, because suitable alternatives – for example Modified Atmosphere Packaging (MAP) –are available.

You can find more information about this list here.