glass for europe statement on food contact materials

Use of flat <strong>glass</strong> <strong>for</strong> food applications is really very limited and rare: flat <strong>glass</strong> is mostly used inbuildings, automotive and solar energy modulesMore than 99% of flat <strong>glass</strong> production is used <strong>for</strong> windows, facades, automotive <strong>glass</strong> and solar energymodules. Only a very small fraction of flat <strong>glass</strong> production (much lower than 1% considering all otherapplications) is used in products intended <strong>for</strong> food contact. Among this limited number of articles can be citedcutting boards, decorative serving plates, tables and counter tops, fridge shelves, etc.Although quantities of flat <strong>glass</strong> products that may have food contact application are almost negligible,demonstration of compliance with new limit values would be required <strong>for</strong> the full flat <strong>glass</strong> production(over 9 million tonnes in the EU), as products’ final destination and usage are not known to the flat <strong>glass</strong>producer at the time of production.Absence of health hazardTesting nowadays per<strong>for</strong>med by flat <strong>glass</strong> companies in order to demonstrate compliance with the existingmigration limits have consistently confirmed, with large confidence, compliance with the limits. Indeed allresults are below the quantification limits of the analytical equipments commonly used in laboratories.In fact, characterization testing per<strong>for</strong>med on flat <strong>glass</strong> products have consistently showed heavy metalstraces within flat <strong>glass</strong> products that are at least between 10 to 100 times lower than the most stringentregulatory limits already set by the EC packaging directive <strong>for</strong> containers of all types, whose primarypurpose, unlike flat <strong>glass</strong>, is to preserve food, ingredients and drinks.Testing conditions not fit to the reality of food contact of flat <strong>glass</strong> productsUnlike other articles potentially targeted by the directive, flat <strong>glass</strong> products that are used <strong>for</strong> food contactpurposes are usually meant <strong>for</strong> short-contact times and a contact with food in the solid state only. Theprescribed testing conditions (24h contact at 22 °C in 4% acetic acid) are not representative of a solidexchange 2 . Such test conditions would there<strong>for</strong>e lead to a major overestimate of the real migration and thusexposure of consumers.A disproportionate burden on producers <strong>for</strong> no public health benefitReconfirming compliance to the newly proposed limits cannot be per<strong>for</strong>med internally by companies since thenew limit values <strong>for</strong> lead and cadmium migration requires specific testing conditions including the use ofultra-pure reagents, clean rooms and the most advanced equipments in terms of accuracy. It would there<strong>for</strong>erequire the testing to be done by specialized external laboratories that present appropriate equipments andexpertise to per<strong>for</strong>m this testing.2 For instance, tests provide results per liter and conversion factors have to be used <strong>for</strong> flat ware. The conversion factor is based on a factor of 6 fromliters to square decimeters (considering the sum of the areas of the 6 faces of a cube of 1 liter), which implies a contact with all faces and the entirearea of each of the 6 faces, which simply cannot physically happen while using products made of flat <strong>glass</strong>.Glass <strong>for</strong> Europe <strong>statement</strong> on Food Contact Materials – January 2013 Page | 2