FCM JEGs Minutes 23rd August 2023

Contents                                                                                                     

Interests

1.             The Chair reminded those attending the meeting to declare any commercial or other interests they might have in any of the agenda items. 

Item 1: Welcome and Apologies 

2.             The Chair welcomed all attendees to the meeting. No apologies were received. Mike Dickinson the Team leader for the FSA Secretariat was introduced to the FCM JEG team as Claire Potter’s replacement.

Item 2:          Matters arising

3.             A dossier update table with the overall progress of all FCM dossiers was presented to the Members.

4.             As part of the dossier updates, the Group received an oral update on the draft safety assessment for RP45, a recycling process dossier, which was to be presented to the Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT) during their September 2023 meeting for approval and thus finalisation of the safety assessment.  

5.             Editorial comments on the update on the draft safety assessment for RP45 were received and will be addressed by the Secretariat.

6.              Several Members of the Group expressed an interest in attending the COT meeting virtually. This would be facilitated by the Secretariat.  

7.             Three dossiers will be presented to Members during the current meeting. It was explained that two additional dossiers are still in the suitability check stage and will be presented at a later meeting. The Secretariat is still awaiting the requested additional information for three dossiers. One dossier will be presented at the October meeting. The final assessment has been signed off by both FCMJEG and COT for one plastic additive and one can coating dossier and the confidentiality for both dossiers is currently under review. Ocean-bound plastics were reviewed at the July FCMJEG meeting, the Secretariat is awaiting the requested additional information. 

Item 3: Minutes of the last meeting – July 2023

Meeting notes 

8.             Members noted that “RP64” should be changed to “RP94” in paragraph 5.

9.             Members were informed that the details of TMBPF-DGE would no longer be confidential. 

10.          Members agreed on standard wording to refer to the FCMJEG for consistency.

11.          Members suggested for to revise the wording in paragraph 32 to “a linear response for the standard curve.”

Minutes of the 23^rd of August 2023 Meeting     

12.          A typographical error and editorial changes were noted.

Item 4: Assessment of a recycling process (RP1862)

13.          No conflicts of interest were declared by the FCMJEG. 

14.          This was the first review performed by the FCMJEG of RP1862, a recycling process (i.e., decontamination process) from post-consumer poly(ethylene terephthalate) (PCR-PET) flakes into PET pellets operated by Biffa Waste Service Limited.

15.          The FCMJEG was requested to review the application and advise on whether the available data provided an adequate basis for a safety assessment of the decontamination process.

16.          Following their review, the Group raised several clarification points which will be sent to the Applicant in a ‘Request for Further Information’ (RFI) letter. The assessment of the decontamination process will be continued at the next available meeting.

Item 5: Review of the first draft Opinion of a recycling process (RP94)

17.          No interests were declared.

18.          The FCMJEG discussed the first draft opinion paper on the safety of the recycled poly(ethylene terephthalate) (PET) decontamination process operated by LINAPC for use in the manufacture of articles in contact with food.

19.          Members requested that the draft opinion paper follow the structure of the RP45 draft opinion paper, which also reviews a recycling process. However, it was acknowledged that there would be some variation due to differences in the migration data between the 2 applications. 

20.          Minor re-wording of paragraph 3 of the summary section was suggested.

21.          The FCMJEG agreed to leave the following statement “toxicological data was not required as the challenge test fulfilled the requirement of the legislation (Regulation no 282/2008)” in the summary section and requested that other opinion papers produced by the Secretariat use this wording.

22.          Members noted that the challenge test demonstrates the decontamination efficiency of the recycled PET and not safety. It was also noted that regulation: EU Directive 2002/72/EC is an older regulation but is still applicable to the application as this was the regulation in place at the time the original assessment of the recycling process was conducted.

23.          The FCMJEG queried the missing units of one of the physical properties of the PET values presented in the application and requested clarification from the applicant in order for the value to be assessed.

24.          The FCMJEG suggested summarising challenge test data presented in text format.

25.          Members also requested that only data that are relevant to the decontamination process conducted by LINPAC are included.

26.          Further editorial comments were suggested by the FCMJEG including modifications to referencing.

27.          Finally, the FCMJEG asked the Secretariat to check the origin of the data on cleaning efficiencies and reduction factors and compare it to Table 3 presented in the 2013 EFSA opinion on the safety evaluation of the following processes based on EREMA Basic technology used to recycle post-consumer PET into food contact materials “Octal”, “Pregis”, “Sabert”, “Linpac”, “ExtruPET”, “Evertis”, “Holfeld”, “Huhtamaki”, “Snelcore”, and “Re-PET”1

Item 6: Policy update

28.          No interests were declared.

29.          The FCMJEG was given an update on Policy’s perspective on the recycling plastic applications process. The FCMJEG was informed that the FSA Policy team gave a presentation to several UK-based recycled plastic operators at the British Plastics Federation shortly after the July FCMJEG meeting.

30.          The presentation set out potential policy options including how UK-based recycled plastic operators could potentially meet the new EU Commission Regulation 2022/1616 requirements for placing recycled plastic material onto the EU market.

31.          Members thanked the policy team for their updates.

Item 7: Update on additional information on a recycling process (RP53)

32.          The Group previously reviewed this application during their February 2023 meeting, after which an RFI letter was sent to the Applicant. This discussion was a continuation of their evaluation in order to review the additional information submitted by the Applicant in response to the RFI. 

33.          Several clarification points were requested by the FCMJEG. 

34.          Otherwise, the additional information was considered satisfactory. The Secretariat will prepare the draft safety assessment. 

Item 8: Any Other Business (AOB)

35.          Members were informed that the next FCMJEG meeting will be a hybrid meeting and will be held at Clive House on the 3^rd of October 2023.

Date of next meeting

36.          The next meeting will be a hybrid meeting at Clive House and will take place on the 3^rd of October 2023.