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Brasil
PackTrends
2020
218
safety & regulatory issues
For active packages that interact with the
foodstuff or the atmosphere around the product two
situations can occur: the absorption of substances
released by food (such as ethylene absorbers) or the
emission of substances (such as antioxidants) that act
on food improving its quality or condition. In this case,
these substances are added to packaging to intentionally
migrate into the food. However, the release of these
substances into the food should be performed under
certain conditions. The substance emitted must be
authorized by food legislation and used in accordance
with the requirements, i.e., the limits established
must be observed independently of the origin of the
substance in food (directly added or via the package)
and be used only for permitted foods. The declaration of
compliance of the packaging is essential in this case to
ensure that consumers are properly informed by the food
manufacturer, and also because this substance should
be declared among the food ingredients on the label.
For substances which have an active or intelligent
function in the package, but should not intentionally
migrate to food and have no function on the food,
safety evaluation studies should be performed and then
submitted to the opinion of the European Food Safety
Authority (EFSA). When authorized these substances
will be listed on a specific Positive List of active and
intelligent packages and their identity, function and
conditions and / or restrictions of use will be described.
It is also important to remember that the materials in
which the active ingredients are incorporated must comply
with specific legislation for that material, for example,
plastic material must meet the regulations for plastics.
In Brazil, nowadays, the use of active and
intelligent packages is restricted to substances described
in the Positive List of packaging materials legislation,
which are restricted to those that should not intentionally
migrate to food and to those substances related in food
laws that will be released and be part of the food. There
is no current requirement to declare the ingredient on
the food label and also no requirement of declaration of
compliance issued by the package manufacturer. It is
expected that in the near future these materials will be
regulated in Brazil and MERCOSUR.
Nanotechnology
The safety of nanomaterial for food contact raises
many questions:
• Does the nanoparticle have potential for migration?
• If so, what is the potential for ingestion of toxic,
carcinogenic or teratogenic substances?
• What are the biological interactions associated with
the presence of the nanoparticle? What is important?
Surface area? Mass? Surface modification with
fillers, for instance?
• What is the biological response to the presence of
nanoscale materials ?
• Do “traditional” toxicology risk studies apply to
nanomaterial?
• How is the consumers exposure to nanoscale
materials characterized?
• How are hazards identified and risks evaluated?
• Are analytical techniques available to detect these
materials effective?
• How are materials with nanometer dimensions
characterized? What equipment should be used?
• How are environmental and occupational questions
relating to nanomaterial answered?
Currently not all questions have answers and there
is still no specific packaging legislation for these materials.
However, in recent years many advances have been observed
in studies on the use of nanoparticles in package materials.
In 2011, the European Food Safety Authority
(EFSA) published a guide containing procedures for
risk assessment of nanomaterial - Guidance on the
risk assessment of the application of nanoscience
and nanotechnologies in the food and feed chain
(GUIDANCE..., 2011). This guide covers the requirements
for physicochemical characterization of nanomaterial
and tests to identify and characterize hazards (in vitro
genotoxicity, absorption, distribution, metabolism and
excretion (elimination) - ADME and oral toxicity studies),
which have their origin in nanoparticle properties such as
size, surface area, reactivity, ability to ‘permeate’ through
biological membranes and so on . The guide also presents
schemes for risk assessment, toxicological evaluation