Over more than a decade, the European Union has been reviewing the monomers and additives which may be used in food-contact plastic applications within the EU. A series of Directives has been produced containing lists of permitted monomers and additives, the lastest being Directive 2002/72/EU which replaced 90/128/EEC.

In Directive 2002/72/EU, colourants are generally not classed as being either "monomers" or "other starting substances". There is a single mention (in Part A of Annex V), but this refers only to organic colourants produced by diazo coupling reactions.

Fortunately, a number of countries established working groups of their own to consider the use of colourants in food-contact plastics while the EU was carrying out its work on monomers and additives. Such a group was established in the UK by the Ministry of Agriculture and JMB had a representative on the group. The main issues considered were the levels of extractable metals in inorganic pigments, toxic impurities in organic pigments and carbon black, together with possible migration of colourants from polymers into food.

The recommendations of the Ministry of Agriculture working group and of those in other contries were passed to the Council of Europe for consideration. They were eventually agreed by the CoE countries (including all the EU member states at the time) and were published as Resolution AP 89(1). A number of countries have since adopted AP 89(1) requirements into their national legislation.

For inorganic pigments, migration does not take place, no organic compounds are present and therefore the only requirements laid down in AP 89(1) are that the pigments themselves should comply with the following limits of extractable metals, using the specified test method:

Element Limit %

antimony 0.05

arsenic 0.01

barium 0.01

cadmium 0.01

* chromium 0.1

lead 0.01

mercury 0.005

selenium 0.01

* the use of Cr(VI) pigments for food-contact use

is discouraged

All JMB cadmium pigment batches are subject to "Council of Europe" testing during production and confirmation of compliance to AP 89(1) can be provided on request. Should information on the actual level of acid-soluble cadmium in a particular material be required, it would help us if this requirement was stated at the time of ordering.

Please feel free to contact us for further information and advice on this subject.

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