A guide into stress-free product compliance

Bamboo and Food Contact Materials (FCM)

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Summary:

  • Bamboo-melamine products are forbidden, because there is no authorisation for bamboo “powder” as additive.
  • Solid bamboo products are not banned; but shall be safe and compliant with national laws.

Do not use bamboo in plastic FCM's

The popularity of bamboo in products that have contact with food is rising. Products sold as ‘natural’ bamboo may in reality be a combination of bamboo and melamine, a plastic. There are risks associated with the release (migration into food) of melamine and formaldehyde from these products. Those risks are not new, they have been reported in the past many times. But the recent surge in sales of those articles resulted in an investigation by the Dutch market surveillance authority NVWA with the following recommendations: 

  • Take action against melamine products exceeding the migration limits (SML) for formaldehyde and melamine. 
  • Investigate the migration of melamine and formaldehyde, especially in consumer products for (small) children.
  • Ban plastic food contact materials with the unauthorised additive bamboo (and/or maize, corn). 

More details can be found in this Statement on bamboo from Belgium, Luxembourg and The Netherlands (Benelux).

Unauthorised natural materials

Polymers, such as melamine, filled with natural materials such as bamboo flower or fibres are considered to be plastic food materials and shall comply with the Plastics Implementing Measure (PIM) Regulation (EU) 10/2011. Such natural materials (additives, constituents) must be explicitly authorised under Article 5 of the PIM Regulation. Bamboo and many other natural constituents are not authorised , so they should not be used in plastic FCM's.
All authorised additives are listed in the so-called Union List, that is included as Annex I of the plastics food contact materials regulation (EU) 10/2011. Keep an eye on the latest edition, the list is updated regularly.

A presentation on EU enforcement actions for bamboo “powder” articles was published in April 2021
The attention for these products will remain and market surveillance authorities will respond to this.

Solid glued bamboo articles

What about “real” bamboo cutting boards?  Solid bamboo is not listed as one of the materials that are covered by specific measures in Annex I of Framework Regulation (EC) 1935/2004. This does not mean that solid bamboo is forbidden to be used as a food contact material. However a cutting board made out of bamboo parings (thin pieces) and/or scraps glued together are made out of two types materials: bamboo and adhesive (glue or binder). 

Although products are not considered as plastic food contact materials, other requirements are applicable in this case.

Both bamboo and glue have to comply with the essential requirements of the EU Regulation 1935/2004, and with a series of national laws. First you need to find out what adhesive (glue, binder) is used for binding the bamboo parings and scraps. Refer to the related ProductIPedia’s articles on adhesives as a food contact material and the processing of bamboo for subsequent information.

Finally, no matter which materials you are selling, make sure the information to the consumer is not misleading.


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