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Pack2Go Europe commissioned new report says EU's single use proposal to restrict food packaging to increase risk of foodborne illness

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Pack2Go Europe commissioned new report says EU's single use proposal to restrict food packaging to increase risk of foodborne illness

September 28, 2018 - 11:53
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BRUSSELS, Sept. 28, 2018 (Press Release) -New report concludes that EU plans to restrict packaging and other items used for serving food will lead to the spread of Salmonella, Verocytotoxigenic E. coli, Listeria, Campylobacter and foodborne viruses that cause acute gastroenteritis.

A new report addresses the significant risk of increased foodborne illness if the EU blindly promotes reusable alternatives to single use food and beverage service packaging in contexts where this is inappropriate, notably where consumers eat and drink out-of-home and on-the-move. The report is by Professor David McDowell, Emeritus Professor of Food Studies at Ulster University and acting chairman of the UK advisory committee on the microbiological safety of food, part of the UK Food Standards Agency.

The report says that, in the absence of radical, significant and unprecedented changes in consumer practice, a ban on or reduced access to food & beverage service packaging and related items will lead to greater persistence and circulation of foodborne pathogens within the human food chain, and increased risks of human foodborne illness in our community.

The European Commission rushed out its proposals in May this year in a bid to reduce the marine littering of plastics but without any assessment of the food hygiene and public health risks. EU environment protection strategy prioritizes reuse as part of the bloc’s overall waste management policy. However, this emphasis on reuse takes no account of the risks to consumer health and safety where food is concerned.

“Even if they think they are doing the job properly, consumers typically fail to clean reusable containers adequately, leaving behind bacteria and viruses that you really don’t want near food,” says Professor McDowell. “They then carry this dangerous material around in reusable bags alongside other items, which also present a high risk of cross-contamination. If consumers bring these containers for refill at takeaway food outlets, coffee shops or even use them with vending machines or water fountains, there is a really high risk that these contaminants will be transferred to other people’s food. That’s exactly what we should be trying to avoid.”

The EU wants to promote reusable containers by restricting access to disposable cups, glasses, trays, boxes and other food containers, cutlery, stirrers, straws and bags, and even to ban some of these items. These are widely used products that are key elements in preventing cross contamination of food products, especially within the retail and consumer stages of the human food chain, like the service of takeaway food and drinks. In effect, the proposal “outsources” responsibility for food hygiene and public health to consumers, hoping that they will clean their re-usable items properly.

“It is of considerable concern to me and a grave omission that the proposal has not been subject to detailed impact assessment for the hygiene, health and safety risks to which it may unintentionally subject EU consumers,” continues McDowell. “These matters merit a much more considered and careful debate by EU legislators than has been the case to date. It would be prudent to avoid unnecessary risks with food safety and public health.”

Many cases of foodborne illness are transient and mild, being limited to malaise, nausea and vomiting. Unreported, these cases are usually resolved without reference to health authorities. However, a significant number of more severe cases of foodborne illness caused by cross contamination within the food chain, involve life-threatening kidney and liver failure, temporary or persistent paralysis, dysfunction of the nervous system and brain, and/or death, particularly among higher risk groups – that is to say, young, old, pregnant or immunocompromised people.

One study cited by Professor McDowell reports a 25% increase in hospital admissions related to foodborne illness, and comparable increases in deaths associated with foodborne infections, in a number of counties in California – after single use grocery bags were banned and replaced with reusable “longer life” bags.

The independent review of the science contained in the McDowell Report was commissioned by Pack2Go Europe, the association of food and beverage service and convenience packaging manufacturers in Europe.

“Our products are designed and used to guarantee food hygiene, protect public health and ensure consumer safety and are vital to the way many people live their lives today. Professor McDowell’s report underlines that they are indispensable in many situations,” says Mike Turner, managing director of Graphic Packaging International Foodservice Europe, and president of Pack2Go Europe. “This is a moment for the EU to take a precautionary approach to health and hygiene – EU citizens do not expect politicians and civil servants to gamble with their wellbeing.”

Pack2Go Europe believes that the unacceptable littering of used packaging and other products by consumers, which has contributed to the presence of plastics in the marine environment, can be reduced effectively by implementing the EU’s newly adopted rules on waste.

“The EU single use proposal should take a positive approach, not a punitive one, by setting collection targets that would accelerate more and better collection and recycling of items used for serving food and drinks,” Turner continues. “That would help deliver a “win-win” situation – less litter and a circular economy for all our products.”

The measures proposed for food & beverage service packaging and related items should be proportionate to the problem they actually pose, especially given that new European rules came into force in June this year that create a true EU policy to address litter and the prevention of littering.

According to surveys used by the European Commission as the basis for its proposal, food & beverage service products account for just 4% of total waste found on beaches and about 8 to 9% of single use plastics items on EU beaches. The same survey shows that plastics bottles and caps, cigarette butts and snack and confectionary wrappers together account for nearly 60% of single use plastics found on beaches, yet no restrictions or bans are proposed for these items.

What precise EU proposals are we talking about? The proposal for an EU Directive on the reduction of the impact of certain plastics products on the environment aims to reduce the amount of plastic litter in oceans and seas. The stated aim of the proposal is to promote more reuse. Fishing (gear) is mentioned over 90 times in the proposal document but human food safety, which will be significantly affected by the envisaged measures, is mentioned just twice, in very brief general statements.

“Foodborne” means that agents of infection like bacteria or viruses are capable of persisting in food or growing on food.

“Foodborne bacteria” – good examples would be Salmonella, Verocytotoxigenic E. coli, Listeria, Campylobacter, all of which can be lethal. Certain “foodborne viruses” (like the norovirus) cause acute gastroenteritis. Both types of “pathogen” are not visible to the eye on reusable containers and not eliminated by light rinsing in water. To sanitize food/drink containers, it is generally recommended that the washing water be around 70-80°C and that detergent is used.

“(Cross)-contamination” is the transfer of bacteria or viruses to people, to food and drink or to food contact surfaces. The term “food contact surfaces” would include containers; food preparation surfaces; protective clothing like sanitary gloves and aprons; coffee and soda machines; the dispensing units of water fountains and vending machine; etc.

How does (cross)-contamination occur? Foodborne bacteria/viruses can get on food or in drinks when the latter are put in contaminated containers or when people handling contaminated containers then handle food. Likewise, they can be transferred to containers from the food and the cycle can go on unless properly sanitized. These bacteria/viruses can also be transferred from container to container by contact with, for example, a vending machine dispensing unit where one or more contaminated reusable containers were earlier refilled and came in contact with the dispenser. To avoid this, most public health authorities recommend/require the use of hygienic single use containers in food service situations or careful sanitizing of reusable alternatives in a well-maintained, professional washing machine.

“Food & beverage service packaging” is a collective term for packs used to serve freshly prepared food directly to customers with the primary intent of guaranteeing food hygiene, reducing the risk of foodborne illness, protecting public health and ensuring consumer safety where reusable alternatives are not appropriate. Good examples are disposable cups, glasses, bowls, trays and other food containers and their lids; plates; boxes; bags; and wraps made from a variety of materials like plastics; paper, board and fibre; metals; wood and combinations of these. They are fully recyclable.

What is specific about this packaging? It is filled at the point of sale (or shortly before sale) and allows customers to safely eat or drink the contents immediately (“buy for now”) or soon after (“buy for later”). Such “takeaway” food and drinks are typically consumed out-of-home and very often on-the-go.

Why are these products considered to be packaging in the EU? Under EU Directive 94/62/EC on packaging and packaging waste, items that contain, protect, handle, deliver or present goods are considered to be packaging, including food & beverage service packs. To avoid confusion, an annex to the directive even specifies that disposable plates are packaging. The 2018 revision of the law sets down ambitious new requirements for collection and recycling of all packaging and also includes measures to tackle litter and littering, which must now be implemented.

“Food & beverage service items” are not “packaging” but they are also used to ensure food hygiene, public health and consumer safety when people are eating and drinking out-of-home or on-the-go. Good examples are drinking straws, disposable cutlery and stirrers.

Where are food & beverage service packaging and related items used? By a wide range of takeaway food outlets; by coffee houses; they are vital for the growing food delivery market; in vending machines; in hospitals, nursing homes, dental surgeries and prisons; in crisis situations; for festivals and events; in private homes; etc. In most of these situations they are indispensable for food hygiene, public health and consumer safety notably because they avoid the cross-contamination that is a high risk with re-usable containers.

Do we really need these products? Yes, there are no practical alternatives in many situations. The reality is that they are indispensable to the way people live today, unless the objective of the EU is to stop people eating and drinking safely on-the-go.

The process for making EU law. First, the Commission is supposed to prepare a proposal based on stakeholder consultation and a detailed and careful assessment of the impact of the proposed measures. Then the European Parliament and the 28 EU member countries brought together in the Council of Ministers review the proposal independently and then negotiate a final law. The European Commission took no account of the food hygiene, public health and consumer safety aspects. So far, health ministers seem to be unaware of the consequences and MEPs and environment ministers are rushing to tackle the environmental aspects without any consideration of the collateral impact on consumer health and wellbeing from increased spread of foodborne illness.

Are food & beverage service packaging and related items the biggest source of marine litter? No, absolutely not. The Commission’s own statistics claim that plastics bottles and caps, cigarette butts, and crisp packets and sweets wrappers account for 60% of the single use plastics litter found on EU beaches. Yet no restriction of these is proposed. Food & beverage service packs and related items together account for 8-9% of single use plastic litter found and 4-5% of all litter found on EU beaches. Yet they are being subjected to the toughest measures – market consumption reduction measures and in some cases bans.

What will be the impacts if these restrictions go ahead? Consumer health and well-being will be put at serious risk, according to Professor McDowell of the University of Ulster. The future viability of the European food service business will be put in question (thought to be worth about 5 to 10% of GDP) and all the jobs it provides.

Information about Professor David McDowell

Professor David McDowell is Emeritus Professor of Food Studies at the University of Ulster.

Since 2010, Professor McDowell has been a member of the UK Food Standards Agency’s advisory committee on the microbiological safety of food. He is deputy chairman and currently acting chairman of the committee and was reappointed for a further two years in May 2018. This non-statutory committee provides expert advice to the UK government on questions relating to microbiological issues and food.

From 1999 to 2010, he was deputy chairman of the scientific advisory committee of Safefood, the agency for the island of Ireland promoting healthy eating and food safety to consumers through integrated, evidence-based marketing and awareness campaigns.

The main focus of Professor McDowell’s academic career has been in food microbiology research, research evaluation, technology transfer, teaching, and the development and dissemination of food safety policy. He has contributed to a wide range of national and international advisory and policy development committees, with particular reference to the ecology, persistence, dissemination and control of foodborne zoonotic pathogens (such as STEC, listeria, salmonella and campylobacter) within the food production, processing and service sectors.

He has considerable experience as a participant in, and an assessor of, a wide range of national and international research projects, as well as leading/supporting subject and policy reviews in food microbiology, food safety, and antibiotic resistance in the human food chain. He is a member of the editorial boards of a number of national and international journals in the above areas, and has published over 170 papers in peer reviewed journals.

Information about Pack2Go Europe

Pack2Go Europe is the leading material neutral European association representing the major food & beverage service and convenience packaging manufacturers who provide innovative single use packaging solutions, including cups, numerous pre-formed containers and enclosures, clamshells, carrier bags, napkins, cutlery and straws.

Since 2012, Pack2Go Europe has played a pioneering role in catalysing the formation of the Clean Europe Network to promote exchange of experience and expertise in relation litter prevention campaigns and behaviour change.

Through its programme “reaching4recycling, calling4collection” the Association is promoting collection and recycling of service packaging around Europe ( A major project has been launched in the UK to collect and recycle paper cups, while cooperation agreements between key stakeholders are underway in Spain and Ireland to launch projects with the potential to be scaled up.

The Association keeps close ties with its U.S. sister association, the Foodservice Packaging Institute.