context on food contact regulation regulation …mireille battaglia quality director verallia france...

CHEMICAL DURABILITY OF OXYDIZED GLASS PRODUCED AT INDUSTRIAL SCALE

-2ND CONFERENCE 22nd - 23rd OF

NOVEMBRE 2019

CONTEXT ON FOOD CONTACT REGULATION

REGULATION AND CONSUMER'S EXPECTATIONS

Mireille Battaglia Quality Director Verallia France – www.verallia.com

VERALLIA, A WORLD LEADER CLOSE TO ITS CUSTOMERS

September 11, 2018Corporate presentation 2018 2

In South America

N°2*

worldwideN°3*

VERALLIAis one ofthe world’s leading manufacturers of glass packaging for food and beverages

in EuropeN°1*

*Management estimate

VERALLIA KEY FIGURES

September 11, 2018Corporate presentation 2018

In €m

Sales 2,474

Adjusted EBITDA 504

(as % of Sales) 20.4%

Capex 236

(as % of Sales) 9.5%

VERALLIA KEY FIGURES

16 billionbottles and jarsproduced in 2017

2017

10,000 employees

3

32 glass productionfacilities

5 technicalcentres

13 product development centres

2400employees

HQ in La Défense, Paris 11 manufacturing facilities

- 2 decoration sites

- 2 glass recycling plants

2 product development centres 1 decoration development centre 1 mobile bottling service 1 distribution centre

September 11, 2018Corporate presentation 2018

JARS

4

Vauxrot

Oiry

St-Romain

Chalon-sur-Saône

Albi (VOA)

Lagnieu

Pont-St Maxence

Cognac

Châteaubernard

Rozet-Saint-Albin

Gensac-la-Pallue

GLASS RECYCLING

DECORATION

MOBILEBOTTLING

BOTTLES

Cap

tion

VERALLIA FRANCE

LOREM IPSUM

1 1.1 EUROPEANREGULATION

1.2 FRENCH REGULATION

1.3 SITUATION IN OTHER COUNTRIES

2 2.1 FORESEEABLEFRENCH REGULATIONTRENDS

3 3.1 SUPRA LEGALEREGULATORYREQUIREMENTS

TO MEETCONSUMERSEXPECTATIONS

03/12/2018 5

LOREM IPSUM

1 1.1 EUROPEANREGULATION 1.2 FRENCH REGULATION 1.3 SITUATION IN OTHERCOUNTRIES




03/12/2018 6

1.1 LA REGLEMENTATION EUROPEENE

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REGULATION (EC) No 1935/2004 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 October 2004 on materials and articles intended to come into contact with food.

COMMISSION REGULATION (EC) No 2023/2006 of 22 December 2006 on good manufacturing practice for materials and articles intended to come into contact with food.

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REGULATION (EC) No 1935/2004

3 key points:

Principle of Chemical Inertness defined in Article 3

Labelling rules defined in Article 15

Traceability requirement (Article 17)

« The traceability of materials and articles shall beensured at all stages in order to facilitate control, the recall ofdefective products, consumer information and the attributionof responsibility. »

CHEMICAL INERTNESS

European Commission: Health and Food Safety Dept is responsible for EU policy on food safety and health and for monitoring the implementation of related laws for materials and articles intended to come into contact with food.

� Commission Dept. of Health and Food Safetybase there statements on the opinions andrecommendations of the European FoodSafety Agency (EFSA) and especially onopinions given by the Panel on Food ContactMaterials, Enzymes, Flavourings andProcessing Aids (CEF Panel) .

03/12/2018 9

LIMITS OF THE EUROPEAN REGULATION

Some materials are not yet subject to specific regulations at EU level.

Inorganic materials:

Partial regulation for traditionnal ceramics basedon the COUNCIL DIRECTIVE 84/500/CEE of 15 October 1984 relating to ceramic articles intended to come into contact with foodstuffs.

03/12/2018 10

RULES ON FREE CIRCULATION OF GOODS IN THE EUROPEAN COMUNITY

Mutual Recognition Principle .

The right to free movement of goods originating in MemberStates, and of goods from third countries which are in freecirculation in the Member States, is one of the fundamentalprinciples of the Treaty (Articles 26 and 28-37 of the TFEU).Free circulation of goods is possible either by means ofCommunity harmonization or by mutual recognition .

Regulation (EC) No 764/2008 , applicable since 13th of May2009, modifies the application of the principle of mutualrecognition: it is no longer for the importer to prove theconformity of a product marketed legally in another MemberState to specific national provisions but it is up to the MemberState to prove the merits of these particular requirementsbased on public interest.

03/12/2018 11


Inorganic materials:

COUNCIL DIRECTIVE 84/500/CEE has been transposed in frenchlaw thru the french order published on the 7th November 1985 andmodified by the order published on the 23rd of May 2006.

No specific regulation concerning glass packaging

In France, regulations are developed by the DGCCRF

03/12/2018 12


In the absence of specific regulation, the DGCCRF writessheets for the different types of materials.

In particular, these sheets specify how to verify theprinciple of inertia of Article 3 of Regulation (EC) No1935/2004 of the European Parliament and of the Council of27 October 2004.

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03/12/2018 14

DGCCRF: Sheet MCDA n°2 (V01 – 01/05/2016)

Specific migration limits depending of the container capacity class:

capacity ≤ 3l and > 3l

Pb and Cd Specific migration Limits in mg/l

Al, Co, As Specific migration Limits in mg/kg*

For packaging, values are obtained after the first extraction (24h) in 4% acetic acid, 22°C and contact duration 24h ± 0h30.

* Limits based on toxicological risk analysis expressed in PTWI (Provisional Tolerable Weekly Intake), Provisional Maximum Tolerable Daily Intake" (PMTDI) - in mg/kg body weight/day or week

03/12/2018 15

Regulation (EC) No 1935/2004 of the Europan Parliament and of theCouncil of 27 October 2004 on materials and articles intended tocome into contact with food.

Different transposition ( Protocol and Limits) depending of the country:

France : Specific migration from DGCCRF: Sheet MCDA n°2 (V01 – 01/05/2016)

Italy : Total migration: Decreto Ministeriale Italiano 21 marzo 1973

Spain : Specific migration : ISO 7086-1 et ISO 7086-2 Glass hollowware in contact with food.

Allemagne : Total + Specific migration : Food Ustensils regulation of the Netherlands – including 328583 – 17560 VGP of 14 Marc h 2014

1.3 SITUATION IN OTHERS EUROPEAN COUNTRIES

Different protocol: Simulant,

Temperature,

Contact duration

Mono or multi extraction.

Different limits

03/12/2018 16

LOREM IPSUM







03/12/2018 17

FORESEEABLE FRENCH REGULATION TRENDS

Regulation:

Sheet MCDA n°2 (V01 – 01/05/2016) Food contact suitability of inorganic materials (excluding metal and alloys) intended to come into contact with food

Applicable to glass packaging intended to come into contact with food

Widely inspired by the Council Directive 84/500/CEE on ceramic articles intended to come into contact with foodstuffs.

03/12/2018 18

The main regulatory requirements on food contact packaging are under revision

It opens an opportunity to hamonize regulations related to ceramics and glass (protocol and limits)

Foreseeable evolution: Decrease in specific migration rates especially for Pb and Cd

For tableware, addition of new elements like Al, Co and As with protocol modification for this type of article: contact duration 2h instead of 24h and 3rd extraction taken into account for all kind of tracked metal.

New specific requirements not directly link to food consideration: BPA , Phtalates

03/12/2018 19

LOREM IPSUM







03/12/2018 20

BENCHMARK WITH REGULATION ON PLASTIC PACKAGING

Today, glass packaging is concerned by the regulation on glass, but not only.

Some specific customers or Commissions linked to dedicated market segments are asking to be also compliant with the Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food

Due to the specificity of the glass, very few labor atories are available to study the conformity of this type of material accor ding to the (EU) 10/2011 regulation, which can cause real problem in some ca ses.

03/12/2018 21

DECLARATIONS / CERTIFICATS OF CONFORMITY OR ABSENCE O F SUBSTANCES ARE OFTEN REQUESTED

- Absence of MOSH – MOAH due to major mass-market retailling actors

- Absence of Controversial substances (endocrine disrupters)

- Absence of Radioactivity (consequence of the Fukushima's nucleare accident)

- Absence of Nanoparticles

- Conformity to HALAL – CASHER requirements

- Bio Packaging – No existing framework for Bio packaging (no possible certification),

- Vegan Packaging – this concept is out of the frame of packaging consideration. It is more an ethic concern which is not compatible with the HACCP obligation (pests controlemeasures).

03/12/2018 22

FEW EXAMPLES OF OUR KNOW -HOW

5 septembre2018Présentation institutionnelle 2018 23*

Château Lagarde(France)

GEM Pays d’Oc(France)

Borgo Molino(Italy)

Diablo(Chile)

Manon AOP Côte de Provence (France)

Adorada(USA)

Reno Hortas(Portugal)

Mar de Frades(Spain)

Lunae Salton(Brazil)

Alma Negra(Argentina)

*

*

Le rhum Plantation(France)

La vodka Ostoya(Poland)

Le gin Sharish(Portugal)

La vodka Liquid(Brazil)

FEW EXAMPLES OF OUR KNOW -HOW

5 septembre2018Présentation institutionnelle 2018 24

L’Amaro Montenegro(Italy)

La vodka BLEUSTORM(Ukraine)*

* *Le Gin MG

(Spain)

Le gin Ada Lovelace(USA) *

*

*

http://verallia.com/

THANK YOU FOR YOUR ATTENTION

context on food contact regulation regulation …mireille battaglia quality director verallia france...

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