AOECS position on Food Contact Materials
Version 1 / 2025
Summary
As part of the shift towards sustainable alternatives to plastic, bio-based food contact materials are increasingly being made from plant-based sources, including gluten-containing cereals.
Scientific evidence shows that gluten can migrate from certain bio-based materials into food, posing a real risk to people with coeliac disease.
However, current EU legislation does not require allergen labelling or specific risk management for food contact materials, leaving consumers unprotected.
The use of bio-based food contact materials must be accompanied by clear allergen information, validated methods to assess allergen migration, and regulatory safeguards to ensure that sustainability objectives do not compromise the safety of people with coeliac disease.
Use of biodegradable material is accelerating
The transition from conventional plastics to bio-based and biodegradable alternatives in food contact materials (FCMs) is accelerating as part of global and EU sustainability efforts. While these materials support environmental objectives, their increasing use also raises new and under-recognised risks for people with coeliac disease and other food allergies.
Evidence of gluten migration from Food Contact Materials (FCM)
Many alternative FCMs are made from plant-based raw materials, including cereals containing gluten, such as wheat, barley and rye. Scientific evidence shows that gluten can migrate from certain bio-based food contact materials into food, in some cases at levels well above the safety threshold for people with coeliac disease. Unlike food products, FCMs are not subject to allergen labelling requirements, leaving consumers unaware of potential exposure risks.
Regulatory gaps to allergen managment in food contact materials
AOECS considers that the current regulatory framework for food contact materials fails to adequately address allergen risks, as it does not require allergen information, lacks validated methods to assess gluten migration from non-food materials, and provides insufficient safety guidance for reusable bio-based products.
Download the full position paper for detailed reading.