464 Novel food packaging gulations omponents Food additive positive lsts? Fig. 22.1 Classification of active and intelligent food-packaging systems in view of current legislation. For a description of categories A-E, see the text(reproduced with permissionfromFoodAdditivesandContaminantsJuly2002.http:/www.tandf.co.uk) Category C: These systems contain components that are included in the positive lists of the EC, but the migration exceeds the migration limit(s) set in the current legislation Category D: These systems contain components that are not included in the positive lists of the EC but are food additives or natural omponents or other components for which toxicological data are
Category C: These systems contain components that are included in the positive lists of the EC, but the migration exceeds the migration limit(s) set in the current legislation. Category D: These systems contain components that are not included in the positive lists of the EC but are food additives or natural components or other components for which toxicological data are Fig. 22.1 Classification of active and intelligent food-packaging systems in view of current legislation. For a description of categories A–E, see the text (reproduced with permission from Food Additives and Contaminants, July 2002. http:/www.tandf.co.uk). 464 Novel food packaging techniques
Legislative issues relating to active and intelligent packaging 465 available. In addition, the migration from the systems exceeds the migration limit(s)set by the EC Category E: These systems contain components that neither are listed nor are food additives or natural components or other components for which no toxicological data are available Most of the systems investigated could be classified into categories A and B Some fall into categories C and D. Only a carbon dioxide-releasing system could not be classified. Generally, it could be concluded that an extension of existing regulations with dedicated requirements seems to be necessary rmit the breakthrough of these materials on the Eu market and to guarantee their safe introduction and use in Europe. The results of the classification have been used to select representative combinations of foods and active and intelligent packaging systems for further validation studies An overview of the food-packaging combinations selected for evaluation of microbiological safety, shelf-life-extending capacity and efficacy of the active and intelligent systems is presented in Table 22.3 Task 3: Evaluation of microbiological safety, shelf-life-extending capacity and efficacy of active and intelligent systems In this task an overall evaluation of the capability (including effectiveness, safety and shelf-life-extending capacity)of the active and intelligent packaging systems was conducted. To this end, the microbiological safety of the test food, packed and stored in active packaging systems, was determined by analyzing their microbiological condition. In addition, the risk of false indication of ntelligent systems was examined. Furthermore, the effectiveness of active Table 22.3 Food-packaging combinations selected for validation studies Packaging system Food Oxygen-scavenging film Fresh pasta Moisture-absorbing p Fresh meat Ethylene-absorbing film Antimicrobial film Cheese Antimicrobial film Meat Antimicrobial film Aldehyde-absorbing film Milk powder Milk powd Antimicrobial sache Sandwich bread Oxygen-scavenging crown Oxygen indicators mea Sliced meat
available. In addition, the migration from the systems exceeds the migration limit(s) set by the EC. Category E: These systems contain components that neither are listed nor are food additives or natural components or other components for which no toxicological data are available. Most of the systems investigated could be classified into categories A and B. Some fall into categories C and D. Only a carbon dioxide-releasing system could not be classified.5 Generally, it could be concluded that an extension of existing regulations with dedicated requirements seems to be necessary to permit the breakthrough of these materials on the EU market and to guarantee their safe introduction and use in Europe. The results of the classification have been used to select representative combinations of foods and active and intelligent packaging systems for further validation studies. An overview of the food-packaging combinations selected for evaluation of microbiological safety, shelf-life-extending capacity and efficacy of the active and intelligent systems is presented in Table 22.3. Task 3: Evaluation of microbiological safety, shelf-life-extending capacity and efficacy of active and intelligent systems In this task an overall evaluation of the capability (including effectiveness, safety and shelf-life-extending capacity) of the active and intelligent packaging systems was conducted. To this end, the microbiological safety of the test food, packed and stored in active packaging systems, was determined by analyzing their microbiological condition. In addition, the risk of false indication of intelligent systems was examined. Furthermore, the effectiveness of active Table 22.3 Food-packaging combinations selected for validation studies Packaging system Food Oxygen-scavenging film Fresh pasta Moisture-absorbing film Fish Moisture-absorbing pad Fresh meat Ethylene-absorbing film Bananas Antimicrobial film Cheese Antimicrobial film Meat Antimicrobial film Fruit Aldehyde-absorbing film Cereal Oxygen-scavenging sachet Milk powder Oxygen-scavenging sachet Biscuits Moisture-absorbing sachet Milk powder Antimicrobial sachet Sandwich bread Oxygen-scavenging crown Beer Time-temperature indicators Fish Oxygen indicators Sliced meat Carbon dioxide indicator Sliced meat Legislative issues relating to active and intelligent packaging 465
466 Novel food packaging Table 22.4 Effectiveness and shel extending capacity of some food/active packaging test combinations Active packaging Food Effective Shelf-life extension Oxygen-scavenging Fresh pasta Yes Yes, longer microbiological shelf-life Moisture-absorbing Pork microbiological shelf-life Antimicrobial film Cheese/ No same microbiological shelf-life bread absorbing Cereals Y Yes, longer sensory and chemical shelf- No, but a good alternative(same sensory and chemical shelf-life)to MAP can packaging O2-absorbing sachet Cooked Yes, longer shelf-life/same microbiological shelf-life O2-absorbing crown Beer Yes lo. same sensorial shelf-life 4 Compared with a food/packaging combination without an active packaging system packaging systems to improve the microbiological stability of food, as compared to traditional packaging systems, was tested. Also the extension of sensory and chemical shelf-life was investigated for different active packaging/food combinations In total, 12 studies were performed to investigate the effectiveness and shelf-life-extending capacity of selected food/active packaging combinations Some typical results are presented in Table 22.4. Most of the active systems investigated appeared to be effective as claimed by their manufacturers. From the shelf-life studies it can be concluded that a number of active ndeed prolong shelf-life. The indication capacity of three time-temperature indicators, two oxygen indicators and a carbon dioxide indicator was investigated. The indicators investigated indicated relatively well the conditions they were meant for(time-temperature history, package headspace oxygen or carbon dioxide) Task 4: Toxicological, economic and environmental evaluation of active and ntelligent systems Intelligent devices and some active systems may contain substances that are not food additives and have not been evaluated by the EU Scientific Committee on Food(SCF) for use in food contact materials. Within the Actipak project it was therefore agreed to study the consequences when a substance is not on the positive list of the directives on food contact materials and to collect and interpret available toxicological data. Examination of existing toxicity data of
packaging systems to improve the microbiological stability of food, as compared to traditional packaging systems, was tested. Also the extension of sensory and chemical shelf-life was investigated for different active packaging/food combinations. In total, 12 studies were performed to investigate the effectiveness and shelf-life-extending capacity of selected food/active packaging combinations. Some typical results are presented in Table 22.4. Most of the active systems investigated appeared to be effective as claimed by their manufacturers. From the shelf-life studies it can be concluded that a number of active systems indeed prolong shelf-life. The indication capacity of three time-temperature indicators, two oxygen indicators and a carbon dioxide indicator was investigated. The indicators investigated indicated relatively well the conditions they were meant for (time-temperature history, package headspace oxygen or carbon dioxide). Task 4: Toxicological, economic and environmental evaluation of active and intelligent systems Intelligent devices and some active systems may contain substances that are not food additives and have not been evaluated by the EU Scientific Committee on Food (SCF) for use in food contact materials. Within the Actipak project it was therefore agreed to study the consequences when a substance is not on the positive list of the directives on food contact materials and to collect and interpret available toxicological data. Examination of existing toxicity data of Table 22.4 Effectiveness and shelf-life extending capacity of some food/active packaging test combinations Active packaging Food product Effective Shelf-life extension * Oxygen-scavenging film Fresh pasta Yes Yes, longer microbiological shelf-life not due to O2 absorption but to barrier characteristics of the active film Moisture-absorbing pad Pork Yes No, same microbiological and sensory shelf-life Antimicrobial film Cheese/ bread Possibly No, same microbiological shelf-life Aldehyde-absorbing film Cereals Yes Yes, longer sensory and chemical shelflife O2-absorbing sachet Milk powder Yes No, but a good alternative (same sensory and chemical shelf-life) to MAP can packaging O2-absorbing sachet Cooked ham Yes Yes, longer sensory shelf-life/same microbiological shelf-life O2-absorbing crown cork Beer Yes No, same sensorial shelf-life * Compared with a food/packaging combination without an active packaging system. 466 Novel food packaging techniques
Legislative issues relating to active and intelligent packaging 467 one substance with oxygen absorption capacity indicated the substance to be potentially mutagenic. This demonstrates that substances used in active and intelligent packaging systems should be evaluated by SCf before allowing them to come in contact with foodstuffs. In other words, they should be evaluated like all other substances used in food contact materials To establish acceptance among European consumers of active and intelligent systems that have been proved to be suitable and safe, these systems were subjected to an international study on consumers attitudes towards application of these systems. This study also provides insights into national differences and general attitudes. Consumer focus groups consisting of 8-12 people of mixed age and sex were formed in six European countries, namely the UK, Italy, Germany, the Netherlands, Finland and Spain. The results demonstrated that for active and intelligent devices to be readily accepted in Europe in the immediate future, their introduction to the marketplace should be supported by a substantial information campaign clarifying their benefits and how they function. They will not gain acceptance purely by virtue of extension of shelf-life. Also, to avoid confusion, some standardization, at least of indicators, would be preferable Attitudes are fairly consistent in Europe with the exception of Spain and possibly Italy. Consumers in Spain were much more ready to accept both active devices(absorbers, including sachets) and indicators, and responded very positively to them. Italy also seemed slightly keener than the rest of Europe The economic consequences and environmental implications of active and intelligent systems were evaluated as part of the project. The shelf-life extending capacity of active packaging is expected to reduce food waste due to spoilage. Consequently, energy and packaging materials may be saved. Multi- layer barrier packaging materials might be replaced by less complicated packaging materials, thus reducing packaging waste. In addition, from the study the conclusion can be drawn that the use of intelligent packaging such as time temperature indicators will decrease the waste generated in the long term Task 5: Recommendations for legislative amendments Finally, all results of the project and the requirements of all relevant EU regulations were evaluated. Based on this evaluation recommendations were drafted for the implementation of suitable active and intelligent systems in relevant European Directives. These recommendations were discussed informally with several national and European authorities. In addition to food kaging regulations, other relevant European regulations were studied such as regulations for food additives, biocides, pesticides, modified-atmosphere packaging, flavouring, food hygiene, labelling, product safety and packaging waste. These regulations generally do not form a serious hurdle to the safe introduction of active and intelligent food packaging systems in Europe. The directive on food hygiene even appeared to be an incentive to the use of active and intelligent packaging The first proposal for changing the framework Directive 89/109/EEC has resulted in a draft amendment of the this directive in which active packaging is
one substance with oxygen absorption capacity indicated the substance to be potentially mutagenic. This demonstrates that substances used in active and intelligent packaging systems should be evaluated by SCF before allowing them to come in contact with foodstuffs. In other words, they should be evaluated like all other substances used in food contact materials. To establish acceptance among European consumers of active and intelligent systems that have been proved to be suitable and safe, these systems were subjected to an international study on consumers’ attitudes towards application of these systems. This study also provides insights into national differences and general attitudes. Consumer focus groups consisting of 8–12 people of mixed age and sex were formed in six European countries, namely the UK, Italy, Germany, the Netherlands, Finland and Spain. The results demonstrated that for active and intelligent devices to be readily accepted in Europe in the immediate future, their introduction to the marketplace should be supported by a substantial information campaign clarifying their benefits and how they function. They will not gain acceptance purely by virtue of extension of shelf-life. Also, to avoid confusion, some standardization, at least of indicators, would be preferable. Attitudes are fairly consistent in Europe with the exception of Spain and possibly Italy. Consumers in Spain were much more ready to accept both active devices (absorbers, including sachets) and indicators, and responded very positively to them. Italy also seemed slightly keener than the rest of Europe. The economic consequences and environmental implications of active and intelligent systems were evaluated as part of the project. The shelf-lifeextending capacity of active packaging is expected to reduce food waste due to spoilage. Consequently, energy and packaging materials may be saved. Multilayer barrier packaging materials might be replaced by less complicated packaging materials, thus reducing packaging waste. In addition, from the study the conclusion can be drawn that the use of intelligent packaging such as timetemperature indicators will decrease the waste generated in the long term. Task 5: Recommendations for legislative amendments Finally, all results of the project and the requirements of all relevant EU regulations were evaluated. Based on this evaluation recommendations were drafted for the implementation of suitable active and intelligent systems in relevant European Directives. These recommendations were discussed informally with several national and European authorities. In addition to food packaging regulations, other relevant European regulations were studied such as regulations for food additives, biocides, pesticides, modified-atmosphere packaging, flavouring, food hygiene, labelling, product safety and packaging waste. These regulations generally do not form a serious hurdle to the safe introduction of active and intelligent food packaging systems in Europe. The directive on food hygiene even appeared to be an incentive to the use of active and intelligent packaging. The first proposal for changing the framework Directive 89/109/EEC has resulted in a draft amendment of the this directive in which active packaging is Legislative issues relating to active and intelligent packaging 467
468 Novel food packaging techniques included in the scope as described in Article 1. It is expected that this amendment will be approved by the end of 2003. This will remove the first barrier to the introduction of active packaging systems in Europe. A more detailed description of the results of this task will be given in section 22. 4 22.3 Initiatives to amend Eu legislation: Nordic report The Nordic countries(Denmark, Finland, Iceland, Norway and Sweden) have a long tradition of co-operation in the food packaging area, and these countries have similar legislation for food contact materials. A project group under the Nordic Council of Ministers has discussed the legal aspects of active and intelligent systems. The project group was chaired by Dr Fabech of the Danish Veterinary and Food Administration. In 2000, the project group published a report on legislative aspects of active and intelligent food packaging. This so- called "Nordic Report aimed at contributing to a solution of legislative problems related to active and intelligent food contact materials. In the first chapter of that report an overview is given of different types of active and intelligent food packaging. The effectiveness of these systems and the test requirements are discussed. The most important part of the report is a comprehensive overview of European legislation relevant to active and intelligent packaging. In section 22.4, a description of these Eu directives given and their relevance to active and intelligent packaging is discussed In the Nordic report recommendations are also given as to which parts of the EU legislation should be reviewed and which questions could be solved through interpretation of existing legislation. Preferably, harmonized legislation should be interpreted on a European basis to avoid divergence in interpretation, which could lead to barriers to trade. Proposals are given for solutions to problems by nterpretation. According to the Nordic group, it is not necessary to introduce new EU legislation. Instead, amendments should be made to existing legislation and guidelines on how to interpret existing legislation should be given. Finally initiatives are proposed to be taken by legislators, both on a national and on an EU level, when drafting new or revising existing legislation on active and intelligent packaging 22.4 Current EU legislation and recommendations for change For this study of relevant European regulations, a schedule was made of the scope of active and intelligent packaging systems. Definitions of active and ntelligent systems are proposed. Based on that principle an overview of the physical appearance of the systems is required as well as a division by functionality of the various systems
included in the scope as described in Article 1. It is expected that this amendment will be approved by the end of 2003. This will remove the first barrier to the introduction of active packaging systems in Europe. A more detailed description of the results of this task will be given in section 22.4. 22.3 Initiatives to amend EU legislation: Nordic report The Nordic countries (Denmark, Finland, Iceland, Norway and Sweden) have a long tradition of co-operation in the food packaging area, and these countries have similar legislation for food contact materials. A project group under the Nordic Council of Ministers has discussed the legal aspects of active and intelligent systems. The project group was chaired by Dr Fabech of the Danish Veterinary and Food Administration. In 2000, the project group published a report on legislative aspects of active and intelligent food packaging. 3 This socalled ‘Nordic Report’ aimed at contributing to a solution of legislative problems related to active and intelligent food contact materials. In the first chapter of that report an overview is given of different types of active and intelligent food packaging. The effectiveness of these systems and the test requirements are discussed. The most important part of the report is a comprehensive overview of European legislation relevant to active and intelligent packaging. In section 22.4, a description of these EU directives is given and their relevance to active and intelligent packaging is discussed. In the Nordic report recommendations are also given as to which parts of the EU legislation should be reviewed and which questions could be solved through interpretation of existing legislation. Preferably, harmonized legislation should be interpreted on a European basis to avoid divergence in interpretation, which could lead to barriers to trade. Proposals are given for solutions to problems by interpretation. According to the Nordic group, it is not necessary to introduce new EU legislation. Instead, amendments should be made to existing legislation and guidelines on how to interpret existing legislation should be given. Finally, initiatives are proposed to be taken by legislators, both on a national and on an EU level, when drafting new or revising existing legislation on active and intelligent packaging. 22.4 Current EU legislation and recommendations for change For this study of relevant European regulations, a schedule was made of the scope of active and intelligent packaging systems. Definitions of active and intelligent systems are proposed. Based on that principle an overview of the physical appearance of the systems is required as well as a division by functionality of the various systems. 468 Novel food packaging techniques