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editorial
. 2020 Mar 3;19:25. doi: 10.1186/s12940-020-0572-5

Table 2.

Topics of concern (based on Table 2 [1]) and examples of activities addressing them. This is not a complete and comprehensive overview but rather a starting point for further discussions that essentially need to involve many stakeholders (see Table 1)

Area Topic Description Example
A. DATA GAPS 1. Information on chemicals used in food contact materials Characterize types of chemicals used in the manufacture of FCMs and FCAs, their functions and levels [67]
2. Information on non-intentionally added substances Compile existing information, develop strategies and work plans to fill data gaps [139, 140]
3. Information on migration of food contact chemicals Provide systematic overview of evidence for migration from FCMs and FCAs [130]
4. Empirical exposure data Measure migration into actual foods, assess intake for different demographics (age groups, ethnic and regional diversity)
B. METHODOLOGY GAPS AND NEEDS 5. Comprehensive definition of adverse effects Expand the scope of toxicological testing requirements to include non-cancer related endpoints such as effects on the nervous, immune and endocrine systems, and cardiovascular and metabolic effects
6. Approaches to addressing non-monotonic dose response Develop practical tools for use in chemical risk assessment of FCCs [119]
7. Approaches to addressing mixture toxicity Develop overall migrate testing for finished FCAs that can be used in the regulatory context, including standardized sample preparation [141]
8. Develop a framework to address aggregate exposures Integrate exposure information from different legislative areas when setting safe exposure thresholds [142]
9. Develop a framework to address cumulative exposures Assess the safety of exposures to different chemicals through the same or different exposure routes
10. Modernize tiered approach for screening and prioritization Include additional relevant endpoints for toxicity testing, include testing of finished FCA
11. Compile information on human health outcomes of exposure to FCCs Assess systematically the available evidence for how FCCs adversely impact human health; highlight data gaps showing the need for appropriate longitudinal studies that assess food contact chemicals [130]
C. UPDATE REGULATORY PROCESSES 12. Overall regulatory framework for evaluation beyond sector-specific regulations Combine chemical hazard and possibly risk assessment for different sectors in one legal framework
13. Requirements for data on use of FCCs Based on the principles of REACH, set legal requirement to provide information about chemical use for market access
14. Need to reassess substances authorized for use and/or generally recognized as safe Policy instruments for removing authorized chemicals e.g. indirect food additives, EU starting substances and additives for plastic FCMs
15. Address bias in risk assessment Ensure that scientific judgement is placed in context of personal values, acknowledge other sources of bias and balance expert groups accordingly
16. Ensure transparency of decisions Communicate potential or real bias of decision makers and experts making recommendations for decision makers
17. Improve enforcement Raise awareness to provide resources for enforcement authorities to expand activities [136]
18. Multi-stakeholder dialogues on practical solutions Address two key topics: 1.) Definition of safety for FCCs: update according to current scientific knowledge; 2.)Food packaging in the circular economy: chemical safety considerations
19. Integrate food packaging waste and safety considerations Policy must address both aspects simultaneously to avoid conflicting goals [138]
D. REPLACING HAZARDOUS FCCs 20. Developing safer alternatives Based on revised definition of safety and updated toxicity testing; develop screening assays for endocrine disruption and other relevant endpoints [134, 143]
21. Testing finished food contact articles Use combination of toxicity testing and chemical analysis (“Effect-directed analysis”) to screen for hazardous but unknown FCCs [95]
22. Integrating human health with environmental considerations: life cycle approach Develop integrative assessment for environmental and human health impacts, e.g. using life cycle analysis or other method [144]
23. Update sustainable packaging concept Define sustainable packaging to also include aspects of human health protection that are based on current scientific understanding