Position statement on food contact materials

AOECS has published a new position statement addressing potential risks for people with coeliac disease linked to certain bio-based food contact materials (FCMs). The position statement calls for greater transparency and regulatory clarity to ensure that people with coeliac disease can make informed and safe choices.

Gluten migration has been documented in studies

As part of the transition away from conventional plastics, food packaging and disposable tableware are increasingly produced from natural raw materials, including cereals such as wheat, barley and rye.

While this development supports environmental sustainability goals, recent scientific studies conducted by AOECS member societies in collaboration with academic partners indicate that gluten can migrate from some of these materials into food.

For people with coeliac disease, even small amounts of gluten can trigger an autoimmune reaction. However, food contact materials are not subject to allergen labelling requirements, meaning consumers currently have no way of knowing whether gluten-containing raw materials have been used.

Evidence and regulatory gaps

Studies within the AOECS network have demonstrated measurable gluten migration from certain cereal-based plates, straws and tableware into food, in some cases significantly exceeding the 20 ppm gluten-free threshold.

Current EU legislation requires that food contact materials must not endanger human health. However, the presence and migration of allergens are not explicitly addressed, and no standardised analytical methods exist to assess gluten transfer from non-food materials.

A call for transparency and updated regulation

AOECS supports the transition towards more sustainable materials and recognises the importance of reducing plastic use. At the same time, consumers with coeliac disease must be given clear information to make informed choices.

AOECS calls for mandatory allergen information on food contact materials, the development of validated testing methods, and the inclusion of allergen considerations in the ongoing revision of EU food contact materials legislation.