The Working Group of Food Chemistry Experts of the Federal States and the Federal Office of Consumer Protection and Food Safety (ALS) published a statement on coatings of food contact materials made from cardboard at their 124th meeting. Specifically, the statement addresses paper cups and similar products coated with acrylate-styrene copolymers (e.g., acrylonitrile-styrene-acrylate copolymer) to create a moisture barrier.
Key Points of the Statement
- Definition of “Plastic”: According to EU regulations (Regulation (EU) No 10/2011, Single-Use Plastics Directive and Labeling Regulation), polymers are generally classified as plastics. This also includes acrylate-styrene copolymers in coatings and varnishes.
- Risk of Misleading Claims: If a coated paper cup is advertised as “plastic-free” or “free from plastic,” this constitutes misleading information within the meaning of Article 3(2) of Regulation (EC) No 1935/2004 and Section 33(1) LFGB. Reason: Consumers associate these claims with environmental benefits that do not actually exist.
- Assessment Consequences: For evaluation purposes, it is decisive that the coatings used are synthetic polymers. Accordingly, they must be legally classified as plastic.
Practical Implications
For manufacturers and distributors of food packaging, this means: Advertising coated paper packaging as “plastic-free” is not permissible if polymer-based coatings are used. Otherwise, legal consequences for misleading claims may result.
Source
The complete statement can be found on the BVL homepage: www.bvl.bund.de/als
Download original text: https://www.bvl.bund.de/SharedDocs/Downloads/01_Lebensmittel/ALS_ALTS/ALS_Stellungnahmen_124_Sitzung_2025.pdf?__blob=publicationFile&v=2
If you would like to have products tested for plastic-free status, contact Dr. Daniel Wachtendorf +49 441 94986-22 and find out more here:
