Long Awaited MERCOSUR Resolution On Additives In Plastic And Polymeric Coatings

The "Common Market of the South" (MERCOSUR), consisting of Brazil, Argentina, Uruguay, and Paraguay, has now published on its website the much anticipated new Resolution on the Positive List of Additives for Use in Plastic Food-Contact Materials and Polymeric Coatings for Food-Contact Materials. This Resolution, designated as GMC Resolution No 39/19, repeals and replaces GMC Resolution No 32/07. It was formally sanctioned by the Common Market Group (GMC), which is the executive body of MERCOSUR, on July 15, 2019. It has been 12 years since this Resolution was last updated in 2007.

The updated Resolution aligns more closely with the European Union's (EU) "Commission Regulation (EU) No. 10/2011 on plastics and articles intended to come into contact with food" (the EU Plastics Regulation) with respect to the requirements imposed on additives used in food-contact plastics. Like the EU Plastics Regulation, all additives that are used in the production of food-contact plastics and intended to be present and function in the finished plastic, must be included on the positive list, which now includes over 1000 substances. Further, substances in nanoform must specifically be listed. Unintentional impurities, akin to Non-Intentionally Added Substances (NIAS) in the EU, including intermediate reaction products and decomposition products, are not required to be included on the Positive List. Further, certain polymerization aids, including catalysts, initiators, accelerators, molecular mass regulators, and REDOX agents are not required to be listed.

The positive list does include certain solvents used in the manufacture of polymers; however, unlisted solvents having a boiling point of less than 150°C also may be used, provided that they are not mutagens, carcinogens, or reproductive toxicants, and further provided that they will not migrate to food at levels greater than 0.01 mg/kg (10 parts per billion (ppb)). In addition, food additives that are...