A guide into stress-free product compliance

Wood & bamboo Food Contact Materials

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

Wood or bamboo as Food Contact Material (FCM)

Both wood and bamboo are commonly used for food contact applications. Besides cutting boards and other kitchen utensils, wood and bamboo are also used for disposable kitchenware as well as for food packaging.
The main difference between woody and herbaceous plants is that the woody plants have a strong stem, which is not easily bendable whereas the herbaceous plants such as bamboo have a flexible stem.
Wood is hard and fibrous structural tissue, it is a natural composite of cellulose fibers. 
Bamboo is essentially fast-growing grass. The chemical composition of a bamboo stem differs from wood.
Bamboo stems contain a large amount of moisture; but also starch and some sugar that must be removed. 
Therefore, bamboo undergoes much more treatments than wood before it can be used in the manufacturing of consumer products. As long as bamboo is treated with traditional methods for removing water, starch and sugar it is a chemical safe food contact material. However modern treatments of bamboo are using chemicals which are hazardous and bamboo treated which these chemical substances are not suitable for food contact applications.

The food contact materials legislation for wooden and bamboo articles is also different.

Wood

Wood is one of the seventeen Food Contact Materials listed in Annex I of Framework Regulation (EC) 1935/2004. 
But there is no harmonised EU directive or regulation for wooden articles. Some EU member states have implemented national legislation for wood; e.g. France and The Netherlands.

Composites

Authorised additives for polymeric (plastic) composites are listed in the so-called Union List, that is included as Annex I of the plastics food contact materials regulation (EU) 10/2011; the list is updated regularly.

“Untreated wood flour and fibers” is entry 96 in the Union List. This means that polymeric (plastic) composites from wood flour or fibres are formally allowed, however it is controversial. The European Food Safety Authority (EFSA) has advised the European commission in November 2019 to reconsider the authorisation of wood as ingredient in the manufacture of composite plastics.

Bamboo flower or fibres are not authorised, they are not mentioned in the Union List. This means that “bamboo-plastic” (e.g. bamboo-melamine) is forbidden for food contact applications. 

Bamboo

Bamboo itself is not listed at all; it is not 1 of the 17 materials in Annex I of Framework Regulation (EC) 1935/2004. Still, products made exclusively from solid bamboo, possibly with a varnish layer or glued, are still allowed. These products must comply with Regulation EC No. 1935/2004, and the national legislation for varnishes and glues.

The ins and outs of glues or adhesives in food contact applications are explained in another resource: Adhesives and Food Contact Materials (FCM)

Varnishes, coatings, oils and waxes

Always verify whether the surface of the wooden or bamboo product has been treated with oil, coating, wax or similar and if glue has been used. If this is the case, the manufacturer should also ensure that these materials are food grade.

Varnishes and coatings are listed as 1 of the 17 food contact materials in Annex I of Regulation (EC) 1935/2004. 

Material specific legislation is (still) not harmonised on European level.  Refer to the Council of Europe (CoE) Resolution ResAP(2004)1 to proof compliance with the requirements for varnishes and coatings.

The best approach to demonstrate safety of wooden and bamboo materials

There is no European legislation for (solid) bamboo in food contact applications. The best approach to demonstrate compliance with the food contact materials regulation is to apply the French or Dutch national measures for wooden food contact materials as a basis for bamboo, and additionally ensure that adhesives, glue, wax, oil when used are also compliant (food grade).

 


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