Paper packaging

 

National legislation

Regulation on Health Suitability of Materials and Articles Intended to Come into Direct Contact with Food
Official Gazette, No. 125/2009 and 31/2011
 

Act on General Use Good (see Article 49, point 2.)
Official Gazette, No. 39/2013, 47/2014, 114/2018 and 53/2022
 

Competent authority

Scope of application

Paper packaging in contact with food
 

Main requirements that the business user needs to know about

Article 100

Paper and cardboard which come into direct contact with the food must meet the following requirements:

• they must release components into food in amounts harmful for human health or which can cause unacceptable changes in the composition of the food or change organoleptic properties of the food.
• they must be produces in accordance with good manufacturing practices for paper and cardboard which come into direct contact with the food, from materials and items used in the production of paper and cardboard, and which are given in recognized lists of raw materials and additives used in the production of paper, cardboard and items which come into direct contact with the food
• they must be of appropriate microbiological quality, taking into account the final use of the material; for materials which come into contact with watery and/or greasy food, special attention must be given to pathogenic microorganisms
• they must not release into food substances with antimicrobial effects
• they must not release more pentachlorophenol than 0.15mg/kg of paper and cardboard
• they must not release more than 0.002 mg of cadmium, more than 0.003 mg of lead, and more than 0.002 mg of mercury, all per dm² of paper or cardboard if during use they come into contact with watery and/or fatty food; this requirement is not checked for paper, cardboard material and items which come into contact with food whose intended use is contact with dry food and food which is peeled and washed before use
• they must conform to all limitations given in recognized raw materials and additives lists for production of paper, cardboard and items; if it can be proven mathematically, taking into consideration the conditions of productions, that limitations for recognized list cannot be exceeded, than it is not necessary to verify whether they conform with the limitations
• paper and cardboard made from recycled fibres can be used as material which comes into contact with food, if they are produced from recycled paper and cardboard of special quality and produced with appropriate procedures and cleaning, in a way which will ensure that the final product meet the requirements of this Regulation
• manufacturers of paper and cardboard which comes into contact with food, must make sure that they use raw materials produced using procedures which reduce dioxins (polychlorinated dibenzodioxins and dibenzofurans) to low levels which can be reasonable achieved.

Article 101

Paper packaging which during packaging comes into direct contact with food can be impregnated with paraffin, wax, coated with protective varnish or polymer material which meet the requirements set out in article 32 through 71 and article 82 of this Regulation.

Paper packaging which during packaging comes into direct contact with food, in addition to items from paragraph 1 of this article can also be impregnated with ammonium bis (N-ethyl-2-perfluoroalkylsulfonamido ethyl) phosphate which contains a maximum of 15% ammonium-mono (N-ethyl-2-perfluoroalkylsulfonamido ethyl) phosphate. If it comes into contact with food at temperatures of up to 66°C, it may release no more than 8.3 mg/dm² of this compound (i.e. 4.4 mg/dm² of fluorine), and if the temperature is above 66°C, it may release no more than 4.3 mg/dm² of this compound (i.e. 2.2 mg/dm² of fluorine).

Provision from paragraph 2 of this article does not pertain to paper packaging used for packaging food which does not contain alcohol or for packaging food which is packed heated at the temperature higher than 220°C.

Article 102

Parchment paper, pergamin paper and other special types of paper which contain no more than 1g of benzoic acid, i.e. 1.2 g sodium benzoate per 1 m² of paper, can be used for packaging food to which preservatives can be added, according to the regulations on food quality.

Papers from paragraph 1 of this article can be used for packaging food to which it is prohibited to add benzoic acid or sodium benzoate, provided that it is proven that the aforementioned preservatives do not migrate to food which comes into direct contact with such papers.

Article 103

Paper packaging may not be dyed if it used for direct packaging of butter, margarine, cream and other dairy products rich in fats and for packaging chocolate, cocoa-based products, powdered milk, powdered eggs, meat products, stuffed puff paste, greasy pastries and table salt.

Packaging from paragraph 1 of this article may have coloured markings on the outside, provided that the dye does not migrate to food.

Paper packaging used for packaging other food, i.e. designations of such packaging may be died with dyes which meet the requirements from Article 13 of this Regulation, provided that the dyes are not soluble in water or fat.

Article 104

Paper, cardboard and items which come into direct contact with food must nor release more than 0.004 mg/dm² of chromium or more than 2 mg/kg of polychlorinated biphenyls.

Dry paper must not contain more than 30 mg/kg of anthraquinone.

There must be no proven enzymatic activity in the finished product.

Packaging from paragraph 1 of this article must not release into extract primary aromatic amines, tetramethylthiuram disulfide, 3,5-Dimethyl-tetrahydro-1,3,5-thiadiazin-2-thione, bromohydroxyacetophenone, disodium cyanodithioimidocarbonate and / or potassium-N-methyldithiocarbamate, potassium-N-hydroxymethyl-N-methyl-dithiocarbamate, sodium-2-oxo-2-mercazole -2 (4-Hydroxy-phenyl) acehydroxime chloride, 2-bromo-2-nitro (1,3) propanediol, 2,2-dibromo-3-nitrile-propionamide, phenyl- (2-chloro-2-cyanide) vinyl) sulfone, phenyl- (1,2-dichloro-2-cyan-vinyl) sulfone, 2-phenyl-sulfonylpropionitrile, phenylsulfonylacetonitrile, 1,2-benzisothiazolin-3-one (bellow the detection limit: 5µg/dm²), 1,2-dibromo-2,4-dicyanobutane (bellow the detection limit: 0,6µg/dm²), β-bromo- β -nitrostyrene (bellow the detection limit: 0,06 mg/kg),hypochlorite, hypobromite, nor methylene-bis-thiocyanate.

Packaging from paragraph 1 of this article must be odourless and must not contain preservatives, unless stipulated otherwise by this Regulation.

Packaging from paragraph 1 of this article must not release into extract more than 1 mg/dm² of formaldehyde.

Article 105

If 2-amino-2-methyl-1-propanol is being used in the production of paper packaging, its may not exceed 0.25 mg/dm² in the extract.

If N- (2-p-chlorobenzoylethyl) is being used in the production of paper packaging, methanol extract must may not contain 2-(p-chlorobenzene) -ethyl-amine.

If 1.4-bis (bromoacetoxy) butene is used in the production of paper packaging, the finished product extract must not contain more than 0.01 mg/dm² of bromine.

If 5-chloro-2-methyl-4-isothiazolin-3-one and 2-methyl-4-isothiazolin-3-one compound, or N-N-dihydroxymethyleneurea, 1,6-dihydroxy-2,5-dioxahexane, 5-chloro-2-methyl-4-isothiozalin-3-one and 2-methyl-4-isothiazolin-3-one compound is being used in the production of paper packaging, the finished product extract must not contain more than 1.0 mg/dm² of formaldehyde and more than 0.005 mg/dm² of isothiazolinone.

If 4,5-dichloro-(3H)-1,2-dithiol-3-one is used in the production of paper packaging, the finished product extract must not contain more than 2.0 mg/dm² expressed for dry fibres.

If glutaraldehyde is used in the production of paper packaging, finished product must not contain more than 2 mg/kg of glutaraldehyde.

If tetrakis (hydroxymethyl) phosphonium sulphate is used in the production of paper packaging, the finished product extract must not contain more than 0,15 ppm of it.

If4,5-dichloro-2-n-octyl-2H-isothiazol-3-one is used in the production of paper packaging, finished product must not contain more than 5 µg/m² of it.

If acrylamide terpolymer, diallyldimethylammonium chloride and glyoxal are used in the production of paper packaging, the extract of the finished product must not contain more than 1.5 mg / m2 of glyoxal.

Article 106

Paper packaging used for packaging citrus fruits (lemons, oranges, mandarins, grapefruit, etc.) may contain a maximum of 0.6 g of diphenyl, calculated on 1 m² of packaging.

Article 107

Parchment and pergamin paper which in packaging comes in direct contact with animal or plant fats, other food with large percentage of fats, meat and meat products, dairy products and powdered eggs must not contain magnesium chloride, and it may contain no more than 2% of other chlorides, expressed as sodium chloride.

Article 108

For paper and items which come into direct food at high temperatures (baking paper), the migration test is carried out using the substitute model solution: modified polyphenylene oxide (MPPO).

For filter papers used to filtrate oils, migration tests are performed using model solutions of olive oil or oil which will be filtered in reality.

For paper used to filtrate large volumes of liquids such as industrial use filters and milk filters, the migration test are carried out:

• if the total volume to be filtered is between 1 to 10 L/dm² of paper, before the testing it is necessary to pass through and reject 0.5L of food or model solution of food, and the next 0.5L/dm² of food or model solution is tested
• if the total volume to be filtered is greater than 10 L/dm² of paper, before the testing it is necessary to pass through and reject 1L of food or model solution of food, and the next 1L/dm² of food or model solution is tested.

Article 109

Paper and cardboard which comes into direct contact with the food, and are made from recycled fibres, must meet all the requirements for paper and cardboard which come into contact with the food and in manufacture special attention must be given to:

• source of paper for recycling
• technology for removing contaminants
• intended use of the finished product.

Article 110

Paper and cardboard which comes into direct contact with the food, and which are produced by recycling, must meet specific requirements given in Table 9, which is enclosed to this Regulation and is an integral part thereof.

 

Market Surveillance Authority

State Inspectorate

pisarnica.dirh@dirh.hr

 

Link to the TRIS database

In the TRIS database you can look up the notification of the technical rule