Controls on chemicals in food

Food contact materials and packaging


Food contact materials are those that are intended to, or can be reasonably expected to, come into contact with food. This can be packaging, cookware, cutlery, tableware, work surfaces or food processing machinery and equipment.

Manufacturers of food packaging materials and producers and sellers of food must ensure that any food contact materials do not present a health risk for consumers or have a detrimental effect on the food, such as alter its taste or aroma.

Food contact materials legislation

The main law is Materials and Articles in Contact with Food Regulations (Northern Ireland) 2012. This implements and enforces a number of EU directives and regulations.

The EU law that continues to apply to Northern Ireland after 1 January 2021 is specified in Annex II to the Northern Ireland Protocol. Food and feed products produced in NI or placed on the NI market need to comply with EU food law. 

EU law on materials and articles intended to come into contact with food sets out the rules on chemical safety and the chemical migration from all materials and articles in contact with food. It includes provisions for materials that will come into contact with foods, such as printing inks and adhesive labels. However, this does not include covering or coating substances that are a part of the food and that may be eaten with it, such as sausage skin.

These general laws are supplemented by specific laws governing particular materials, such as rules on plastics and 'active and intelligent' food contact materials. It also ensures that these materials do not change the nature, substance or quality of the food they are in contact with.

Active and intelligent food packaging materials

It includes descriptions of 'active' and 'intelligent' food packaging materials:

  • active materials - release a substance into the foodstuff to extend its shelf life, or maintain or improve its condition
  • intelligent materials - monitor the condition of the food or its surrounding environment inside packaging and communicate this to the consumer - eg a label which changes colour if it detects bacteria or gases, indicating that the food is not fresh

The Food Standards Agency (FSA) is responsible for ensuring the public is protected against chemicals that might transfer onto food from materials they come into contact with and may carry out food contact materials research to detect chemicals that have transferred to the food.

Documenting food packaging materials

If there are specific measures in place for food packaging materials intended for use in contact with food, for example - plastic, these have to be accompanied by a legal document called a Declaration of Compliance (DoC) and have supporting documentation to back up its assurances of compliance.

All food packaging businesses - apart from the primary materials producers - are required by law to establish and document good practices and procedures in accordance with good manufacturing practice.