Assurance of compliance within the production chain of food contact materials by good manufacturing practice and documentation – Part 1: Legal background in Europe and compliance challenges

EU legislation requires that compliance of food contact materials with the legal requirements must be assured at each stage of the supply chain. The process has to respect good manufacturing practice (GMP), and for this purpose GMP is defined as the tool to ensure compliance. Communication through the production chain is an essential part, clarifying which work has been done and what is delegated to subsequent business stages. At early production stages it is often not possible to conclude on compliance of the final material or article. For instance, migration can only be measured from the final material and compliance of a non-regulated substance may be uncertain at an early stage. In fact, assuming responsibility either means concluding compliance with justification in the supporting documentation or specifying the work to be done at later stages in the documentation accompanying the product. This paper interprets existing legislation and indicates difficulties regarding the needs of food business operators and the role of the enforcement authorities.