No C 230/8 Official  Journal  of the European  Communities 10. 9. 81 
Opinion  M die proposal  for a Council  Directive  on the approximation  of the laws  of the 
Member  States  relating  to materials  and articles  made  of regenerated  cellulose  film  intended  to 
come  into  contact  with  foodstuffs 
The text  referred  to the Committee  has not yet been  published  in the Official  Journal  of the 
European  Communities. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 10 February  1981  the Council  referred  the abovementioned  proposal  to the Economic  and 
Social  Committee  in accordance  with  Article  100  of the Treaty  establishing  the European 
Economic  Community. 
B. OPINION  OF THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and Social  Committee  prepared  its opinion  on the above  matter  at its 189th 
plenary  session  held  in Brussels  on 1,2  and  3 July  1981. 
The full text of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the Treaty  establishing  the European 
Economic  Community,  and  in particular  Article  100 
thereof, 
Having  regard  to the request  made  by the Council  of the 
European  Communities  on 10 February  1981  for an 
opinion  on the proposal  for a Council  Directive  on the 
approximation  of the laws  of the Member  States  relating 
to materials  and  articles  made  of regenerated  cellulose 
film intended  to come  into  contact  with  foodstuffs, 
Having  regard  to the decision  taken  by its Bureau  on 
24 February  1981,  instructing  the Section  for Protection 
of the Environment,  Public  Health  and Consumer  Affairs 
to draw  up an opinion  on the matter, 
Having  regard  to the opinion  issued  by the Section  at its 
63rd  meeting  on 2 June  1981, 
Having  regard  to the oral  report  made  by the rapporteur, 
Mr Ramaekers, 
Having  regard  to the discussions  at its 189th  plenary 
session  held  on 1,2  and  3 July  1981  (meeting  of 1 July 
1981), 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a unanimous  vote: 
1. General  comments 
The Committee  supports  the desire  of the Commission  to 
implement  die outline  Directive  of 23 November  1976  on the approximation  of the laws  of the Member  States  on 
materials  and articles  intended  to come  into  contact  with 
foods  (*). In the Committee's  view  there  is a need  for 
specific  Directives  for a series  of reasons:  to remove 
technical  barriers  to trade,  to protect  the  health  of 
consumers  and to prevent  any unacceptable  change  in the 
composition  and  organoleptic  characteristics  of foods. 
The Committee  approves  the approach  adopted  by the 
Commission  to deal  with  regenerated  cellulose  film, 
namely  the formulation  of list of substances  authorized 
for use in the manufacture  of this  product. 
In view  of the difficulty  of monitoring  the migration  of 
substances  in simulator  liquids,  the Commission  has 
considered  it preferable  to apply  the restrictions  on the 
use of the substances  under  consideration  by means  of 
limits  on the quantity  of these  substances  permitted  in the 
finished  products,  rather  than  limits  on the quantity  of the 
substances  which  may  migrate  towards  foods.  The 
Committee  accepts  this approach. 
In the case  of polymers,  however,  which  are  plastic 
materials,  the Committee  considers  that  it would  be 
advisable  to consider  both  regulating  the  residual 
quantity  of monomers  in the material  and  setting  a 
specific  migration  limit  for the monomers. 
The Committee,  therefore  calls  upon  the Commission  to 
propose,  as soon  as possible,  a list of authorized  plastic 
materials  together  with  specific  migration  limits  for 
monomers  and a polymer  residue  limit. 
In this context  the Committee  would  draw  attention  to 
the importance  of the proposal  for a Directive  on the 
(») OJ No L 340,  9. 12. 1976. 
10. 9. 81' Official  Journal  of the European  Communities No C 230/9 
overall  limit  for the migration  of the constituents  of 
plastic  materials  and  articles  intended  to come  into 
contact  with  foods. 
The Committee  also  wonders  whether  it is always 
advisable  to authorize  such  a large  number  of 
substances. 
It cannot  be denied  that  the use of this approach  makes  it 
possible  to avoid  an accumulation  of one  particular 
undesirable  substance.  On  the  other  hand,  the 
authorization  of a large  number  of substances  can only 
increase  the possible  risk  of synergism. 
2. Specific  comments 
The Committee  approves  all the articles  of the Directive 
but would,  nonetheless,  make  the  following 
comments: 
Article  1 
The Committee  accepts  the exclusion  of synthetic  casings 
from  the scope  of the Directive.  It is a fact  that  the 
substances  used  in the manufacture  of these  products 
differ  from  those  used  in the manufacture  of regenerated 
cellulose  film. 
The Committee  would,  however,  call  upon  the 
Commission  to submit  at the earliest  possible  date  a 
Done  at Brussels,  1 July  1981. proposal  for  a Directive  on synthetic  casings  of 
regenerated  cellulose. 
Article  2 
The Committee  urges  that  the methods  for determining 
the non-migratability  of colouring  matters  and the purity 
criteria  used  for these  substances  be harmonized  without 
delay  so as to avoid  any technical  barriers  to trade. 
Article  4 
In order  to enable  consumers  to distinguish  without 
difficulty  the side of the film  which  may  come  into contact 
with food  from  the side  which  may  not,  the Committee 
proposes  that  the Directive  stipulate  that  the latter  must 
be clearly  indicated,  using  a wording  such  as: 'This  side 
must  not be brought  into  contact  with  food'. 
Article  5 
The Committee  considers  that  the  socio-economic 
interest  groups  concerned  should  be consulted  prior  to the 
amendment  of the Directive  or its Annexes. 
Annexes 
See general  comments. 
The Chairman 
of the 
Economic  and  Social  Committee 
Tomas  ROSEINGRAVE