Argentina Implements New Technical Requirements for Food-Contact Cellulosic Materials and Containers

Argentina has incorporated into its domestic legal regime (1) Mercosur Common Market Group Resolution 40/15 on cellulosic materials, containers and equipment intended to be in contact with food and (2) Mercosur Common Market Group Resolution 41/15 on cellulosic materials for cooking and hot filtration. Compliance with these regulations will be required from 16 July, except for the specific migration limit for anthraquinone which will apply from 31 December 2020 (until that time, subject merchandise must comply with a maximum limit of 0.1 milligrams of anthraquinone per kilogramme of food).

GMC 40/15 covers materials, containers and equipment with a surface made of a cellulosic material or cellulose coated or treated with certain waxes, paraffin, mineral oils and/or mineral pigments that is intended to be in contact with food or food raw materials. Also covered are containers and equipment having several layers made from one or multiple materials with a cellulosic surface intended to be in contact with food or food raw materials, as well as containers and equipment containing certain recycled cellulosic fibres.

Cellulosic materials, containers and equipment must be manufactured in accordance with good manufacturing practices and be suitable to be in direct contact with food. They must not transfer any hazardous substances to food under reasonably foreseeable conditions of use and, if such migration occurs, the substances must not cause an unacceptable modification of the composition or the sensory characteristics of the food. Part II of GMC 40/15 sets forth the substances that may be used in the production of food-contact cellulosic materials, containers and equipment, as well as restrictions on materials, containers and equipment coated or treated with waxes, paraffin, mineral oils and mineral pigments.

The regulations set forth a general maximum migration limit of 8 mg/dm2 for cellulosic containers and equipment in direct contact with food as well as specific limits on such substances and metals as polychlorinated biphenyls (5 mg/kg), pentachlorophenol (0.15 mg/kg), cadmium (0.5 ug/g), lead (3 ug/g), mercury (0.3 ug/g), arsenic (0.01 mg/kg, if there are no specific limits on arsenic at the Mercosur or country level), chromium (0.05 mg/kg, if there are no specific limits on chromium at the Mercosur or country level), antimony (0.04 mg/kg), boron (0.5 mg/kg), barium (1 mg/kg), copper (5 mg/kg), tin (1.2 mg/kg), fluorine (0.5 mg/kg), silver (0.05 mg/kg) and zinc (25 mg/kg). The maximum limits on the aforementioned metals do not apply to cellulosic materials in contact with dry, non-fatty foods. The regulations also establish requirements on the transfer of antimicrobial constituents as well as other provisions.