COUNCIL OF EUROPE
COMMITTEE OF MINISTERS
(PARTIAL AGREEMENT IN THE SOCIAL AND PUBLIC HEALTH FIELD)
RESOLUTION AP (89) 1
ON THE USE OF COLOURANTS IN PLASTIC MATERIALS
COMING INTO CONTACT WITH FOOD
(Adopted by the Committee of Ministers on 13 September 1989
at the 428th meeting of the Ministers' Deputies)
The Representatives on the Committee of Ministers of Belgium, France, the Federal Republic of
Germany, Italy, Luxembourg, the Netherlands and the United Kingdom of Great Britain and Northern
Ireland, these states being parties to the Partial Agreement in the social and public health field, and the
Representatives of Austria, Denmark, Ireland, Norway, Spain, Sweden and Switzerland, states which
have participated in the public health activities pursued within the above-mentioned Partial Agreement
since 1 October 1974, 2 April 1968, 23 September 1969, 11 July 1979, 21 April 1988, 10 June 1975
and 5 May 1964 respectively,
Considering that the aim of the Council of Europe is to achieve a greater unity between its members
and that this aim may be pursued, amongst others, by common action in the social and public health field;
Having regard to the provisions of the Brussels Treaty signed on 17 March 1948, by virtue of which
Belgium, France, Luxembourg, the Netherlands and the United Kingdom of Great Britain and Northern
Ireland declared themselves resolved to strengthen the social ties by which they were already united;
Having regard to the protocol modifying and completing the Brussels Treaty, signed on 23 October
1954 by the signatory states of the Brussels Treaty, on the one hand, and the Federal Republic of Germany
and Italy, on the other hand;
Observing that the seven states parties to the Partial Agreement which have continued, within the
Council of Europe, the social work hitherto undertaken by the Brussels Treaty Organisation and then by
Western European Union, which derived from the Brussels Treaty as modified by the protocol mentioned
in the fourth paragraph above, as well as Austria, Denmark, Ireland, Norway, Spain, Sweden and
Switzerland, who participate in Partial Agreement activities in the field of public health, have always
endeavoured to be in the forefront of progress in social matters and also in the associated field of public
health, and have for many years undertaken action towards harmonisation of their legislation;
Having regard to the fact that colourants are used to impart a colour to plastic materials coming
into contact with food;
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Forty years
Council of Europe
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Considering that plastic materials coming into contact with food may, by reason of their colour-
ation, pose a risk to human health if not used under normal conditions or if the colourants used do not
meet purity criteria based on good manufacturing practice;
Taking the view that each member state faced with the need to introduce regulations governing this
matter would find it beneficial to harmonise such regulations at European level,
Recommend that the governments of the states parties to the Partial Agreement as well as the
governments of Austria, Denmark, Ireland, Norway, Spain, Sweden and Switzerland take into account
in their national laws and regulations the principles set out in this resolution and the analytical methods
and, in particular, specifications on the use of inorganic cadmium pigments set out in the appendix to this
resolution.
Appendix to Resolution AP (89) 1
I. Field of application
This resolution applies to the use of colourants in plastic materials and articles coming into contact with food.
Colourants are substances which are intentionally added to plastics to impart colour; they include dyes, organic and
inorganic pigments.
II. General principles
1. Migration from the final plastic material or article
Under normal or foreseeable conditions of use, plastic materials and articles should not, by reason of their
colouration, pose a risk to human health or bring about either a deterioration in the organoleptic characteristics or
an unacceptable change in the nature, substance or quality of the food with which they come into contact.
Colourants should be sufficiently integrated within plastic materials and articles so as to preclude any visible
migration into foodstuffs under normal conditions of use, as determined by an appropriate method.1
2. Specification
The colourants to be tested should be the active ingredients and not the active components predispersed in a
medium to facilitate good distribution during processing of the plastic materials.
The colourants should meet the purity criteria of the provisions 2.1 - 2.4 and be based on good manufacturing
practice.
2.1. Metals and metalloids
The content of metals and metalloids soluble in 0.1M hydrochloric acid, determined as a percentage in relation
to the colourant, should not exceed:
antimony: 0.05%
arsenic: 0.01%
barium: 0.01%
cadmium: 0.01%
chromium 2 : 0.1%
lead: 0.01%
mercury: 0.005%
selenium: 0.01%
The analytical method is described in section III, paragraph 2.
1. It should be noted that, under normal or foreseeable conditions of use, the specific migration of aromatic amines and of metals
from the finished plastic materials or articles should not exceed the limits specified in the Council of Europe booklet Substances
used in plastics materials coming into contact with food (1).
2. The use of chromium VI pigments may pose a risk to human health and should be discouraged.
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2.2. Aromatic amines
The content of primary unsulphonated aromatic amines soluble in 1M hydrochloric acid and expressed as
aniline should not exceed 500mg/kg. The content of benzidine, ß-naphthylamine and 4-aminobiphenyl, singly or in
total, should not exceed 10mg/kg. 1 The analytical methods are referred to in section III, paragraph 3.
2.3. Sulphonated aromatic amines
Sulphonated aromatic amines are defined as those compounds sulphonated on all aromatic or conjugated ring
structures.
The total content of sulphonated aromatic amines extracted by a suitable solvent and determined by an
appropriate test, expressed as aniline sulphonic acid, should not exceed 500mg/kg. This limit can be exceptionally
exceeded if adequate supporting data on the technological need are provided. An analytical method is discussed in
section III, paragraph 4.
2.4. Carbon black
Carbon black should comply with any national requirement for food grade material. Furthermore, the toluene-
extractable fraction of carbon black should not in any case exceed 0.15% in accordance with the method described
in section III, paragraph 5.
2.5. Polychlorinated biphenyls (PCBs)
The content of extractable polychlorinated biphenyls should not exceed 25mg/kg, expressed as
decachlorobiphenyl, as determined by an appropriate method indicated in section III, paragraph 6.
2.6. Inorganic cadmium pigments
A number of national and international authorities have recommended that the intake of cadmium by man
should be reduced as far as possible. Furthermore, environmental contamination by cadmium is a recognised inter-
national problem. Consequently, a number of regulatory authorities have either taken steps to reduce the total
industrial use of cadmium or are actively considering such measures.
The use of inorganic cadmium pigments in plastic materials and articles coming into contact with food is small
but, in certain applications, such use is claimed to offer major technological advantages. The migration of cadmium
from the use of such pigments is, in general, very low but extraction can vary from plastic type to plastic type. Thus,
the use of inorganic cadmium pigments in plastics coming into contact with food will probably make only a minor
contribution to man's total intake. However, in order to keep the contamination of food with cadmium in general
as low as possible, the use of such pigments should be restricted to applications where their special technological
advantages cannot be met by alternative products.
3. Toxicological tests
Toxicological data should be obtained from pages 71 to 77 of the Council of Europe booklet Substances used
in plastics materials coming into contact with food (1).
III. Analytical methods
1. Determination that there is no visible migration
1.1. Apparatus
- filter paper for qualitative analysis, of medium porosity such as Weissband Mittel (Schleicher and Schull),
chromatography paper (Archer, 302), etc.;
- glass desiccator or other suitable sealed container;
- oven regulated at 50° ± 2°C.
1.2. Simulants
- distilled water or water of equivalent quality;
- 3% acetic acid (w/w) in aqueous solution;
- 15% ethanol (v/v) in aqueous solution;
- decolourised edible oil or fat or a comparable synthetic triglyceride.
If foods do not correspond to the above simulants, for example because of high acid or alcohol content, the
simulants should be modified accordingly.
1.3. Contact surface
At least 10cm2.
1. In normal use, therefore, the quantity of these substances which may migrate into food will be toxicologically insignificant.
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1.4. Operating procedure
Impregnate strips of filter paper with the simulant(s) for the food(s) intended to come into contact with the
material. These strips should have a contact surface of 10 to 15cm2. Eliminate excess simulant by wringing the strips
between two glass rods.
Place the impregnated strips onto the food contact surface of the material or article to be tested, so that there
is intimate contact, and fix with non-coloured adhesive tape. Ensure that there are no air bubbles between the surface
of the sample and the impregnated paper and verify that the latter exerts an even pressure on the sample after the
adhesive tape is affixed.
A simpler method of attachment may be applied in the case of flat samples. On a glass plate, place consecu-
tively 100cm2 of sample and a few impregnated strips, cover with a further flat glass plate and apply a weight of
approximately 1kg.
Impregnate additional strips of filter paper with simulant to act as blanks. It is important that these do not come
into contact with any coloured materials or articles.
Place samples and blanks in a desiccator and maintain for five hours in an oven regulated at 50° ± 2°C.
Where an aqueous simulant is used, it is necessary to transfer a portion to the desiccator and maintain at 50° ± 2°C
for thirty minutes prior to use. This will ensure that the atmosphere in the desiccator is saturated with the vapour
of the simulant.
After the set contact time, separate the strips of impregnated filter paper from the samples and isolate the blank
strips. In the case of aqueous simulants, place the strips in the oven at 50° ± 2°C until the impregnated liquid has
evaporated (approximately fifteen minutes). In the case of the oil simulant, allow the strips to cool.
1.5. Assessment of visible migration
Compare the strips that have been in contact with the sample with the blank strips; these should have remained
colourless. The visual comparison of strips is undertaken in daylight (2). The plastic materials or articles meet the
requirements if comparison of test strips and blank strips reveals no difference.
2. Determination of metals and metalloids
2.1. Apparatus
- agitation device having a rotary mechanical agitator, non-magnetic, with a speed sufficient to maintain the
colourant in suspension but without causing air bubbles to be formed;
- membranefilterwith 0.15 micrometre porosity.
2.2. Reagent
- hydrochloric acid 0.1M of analytical purity.
2.3. Operating procedure (3)
Place in suspension for fifteen minutes, at 23° ± 3°C, 10g of colourant in 150ml of 0.1M hydrochloric acid,
using a mechanical agitator. Filter the acid solution, after sedimentation of the colourant for ten minutes, through
the membrane filter. The filtrate is then analysed for elements mentioned under section III. 1 in accordance with
known methods, for example (4 to 6). Blank determination on reagents is essential.
3. Determination of primary unsulphonated aromatic amines
An extract containing the aromatic amines is prepared by treatment of the organic colourant with 1M
hydrochloric acid as described in ETAD Method No. 212 (7). The quantitative determination of primary un-
sulphonated aromatic amines in this extract may be undertaken either according to this method or to specific methods
(8-11).
4. Analytical methods for the determination of aromatic aminosulphonic acids
The pigments are extracted with a suitable solvent (for example acetic acid, diluted sodium hydroxide solution,
methanolic ammonia or 1 N HCl, as described in ETAD Method No. 212) and the aminosulfonic acids in the extracts
determined by thin layer chromatography. On the TC (toluene column), the compounds are identified by colour
reaction (for example diazotation and coupling with N-(1-naphthyl)-ethylene-diamine or with R salt) and the quantity
determined by comparison with standards of the compounds.
5. Determination of the toluene-extractable fraction of carbon black
5.1. Principle (12)
Carbon black is extracted in a Soxhlet apparatus with toluene. Thereafter, the solvent is evaporated and the
residue weighed.
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5.2. Apparatus
- Soxhlet extraction apparatus;
- extraction vessels of paper fibre, capable of containing 10g of carbon black;
- laboratory glassware;
- oven, adjustable up to 140° ± 5°C.
5.3. Solvent
Toluene.
5.4. Operating procedure
Dry a sufficiently large sample of carbon black for one hour at 105° ± 2°C. Place 10g of the dried carbon
black (weighed with an accuracy of 0.1g) in an extraction vessel previously washed with toluene. Close the vessel
with cotton previously washed with toluene and place the vessel in the Soxhlet apparatus.
Extract the carbon black for eight hours with 150ml toluene. Adjust the heating element of the apparatus in
such a way that the extraction solvent in the extraction vessel is replenished approximately ten times per hour.
Allow to cool, remove the extraction vessel from the apparatus and concentrate the extract to a small volume
by evaporation. Wash the residue with a little toluene into a weighed glass crucible (weight: a g) and remove the
toluene by evaporation on a water bath. Place the crucible in an oven for two hours at 140°C; allow to cool in a
desiccator and reweigh the crucible (weight: b g).
5.5. Calculation
Calculate the extractable fraction E of the carbon black using the following formula:
E = 10 (b - a)%
E shall not exceed 0.15%.
6. Determination of extractable polychlorinated biphenyls (PCBs)
Polychlorinated biphenyls (PCBs) are extracted from organic colourants and determined as specified in the
various methods described in the literature (13). For the determination of very low levels of PCBs (<5 mg/kg), it
is necessary to use methods (14, 15) based on gas chromatography/electron capture and capillary gas
chromatography/electron impact mass spectrometry.
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Literature references
1. Council of Europe, Substances used in plastics materials coming into contact with food, 2nd edition,
Strasbourg, 1982.
2. ETAD Analytical Method No. 221, Quantification of the limits of "No visible migration" of synthetic organic
pigments under conditions of testing using the paper contact method, December 1980. Methods available on request
at ETAD, P.O. Box, CH-4005 Basel 5, Switzerland.
3. ISO, 3856 Method. Paints and varnishes - Determination of "soluble" metal content, 1984, DIN (53777)
Part I, Extraction method.
4. Welz, B., Atomabsorptions-Spektrometrie, 3. Auflage, Verlag Chemie, Weinheim, BRD, 1983.
5. Bertin, E.P., Introduction to X-ray Spectrometric Analysis, Plenum Press, New York, London, 1978.
6. Jenkins, R., Gould, R.W., Gedcke, D., Quantitative X-ray Spectrometry, Marcel Dekker Verlag, New York,
Basel, 1981.
7. ETAD Analytical Method No. 212, Determination of unsulfonated primary aromatic amines in pigments and
in solvent soluble dyestuffs intended for use in food packaging, November 1984.
8. Vantudler, P.J.M., Howard, C.C., Riggin, R.M., "HPLC determination of aromatic amines in body fluids
and commercial dyes", ACS Symp. Ser. 149, 1981, pp. 415-427.
9. Baumann, U., Marek, B., "Bestimmung migrierter aromatischer Amine in Lebensmittelsimulantien", Mitt.
Gebiete Lebensm., Hyg. 71, 1980, pp. 468-483.
10. Hunziker, R.R., Miserez, A., "HPLC-Bestimmung primärer aromatischer Amine in synthetischen Farbstof-
fen für Lebensmittel", Mitt. Gebiete Lebensm., Hyg. 72, 1981, pp. 216-223.
11. Fishbein, L., "Analysis of carcinogenic and mutagenic aromatic amines: An overview", Current Topics in
Environmental and Toxicological Chemistry, Vol. 3, pp. 115-138, Frei, R.W., Brinkman, U.A.Th. (eds.), Gordon
and Breach Science Publishers, London, 1981.
12. German Standard DIN 53553, Bestimmung der mit Lösungsmitteln extrahierten Bestandteile, Verlag Benth
Vertriebs Gmbh, D-1000 Berlin, Burggrafenstr. 7, oder D-5000 Köln, Friesenplatz 16.
13. Bankmann, E., Hotz, R., Prandi, C., Sharples, W.G., Steuerle, G., Stori, M., Weis, H., Zatka, A.,
"Determination of low levels of chlorinated biphenyl impurities in pigments", Chemosphere, 13, 1984, pp. 499-506.
14. US EPA. ORD Environmental Monitoring and Support Laboratory, "Test Method: Organochlorine Pesticides
and PCBs-Method 608", July 1982.
15. US EPA. OPTS. "Practical Limit of Quantification of EPA Method 608 for the Use of Aroclor Analysis of
all waste waters", 5 June 1984.
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