Chapter 12: implementation of monitoring programme for the food contact materials

PLAC III project has provided assistance to the Serbian Ministry of Health in developing the legislation and a guide which will determine the implementation of a monitoring programme for the materials and articles intended to come into contact with food and products of general use in accordance with the risk assessment, product categories monitored and sources of financing.

The activity falls under the scope of the Negotiation Chapter 12. The Republic of Serbia is intensively preparing for negotiations with the EU regarding this chapter.

The EU requirements on materials and articles intended to come into contact with food are governed by Regulation (EU) 1935/2004 and Commission Regulation (EC) 2023/2006. In particular, Regulation (EU) 1935/2004 lays down common rules for packaging materials and articles such as bottles and containers, which come, or may come, into contact with food, either directly or indirectly. It seeks to protect human health and consumers’ interests as well as ensure that the products used may be sold anywhere in the European Economic Area. Commission Regulation (EC) No 2023/2006 lays down rules on good manufacturing practice (GMP) for materials and articles that come into contact with food. Furthermore, the overall product safety monitoring system of the Member States must be aligned with relevant general product safety requirements laid out in Chapter 28 acquis.

In Serbia, the area of food contact materials and articles is governed by the Law on Food Safety and by the Law on Products of General Use, which provide the basis for harmonisation with relevant Union acquis. According to the 2021 Country Report, Serbia should, among other, consistently apply and improve the risk-based approach to sanitary control at borders. The Ministry of Health is responsible for adoption of  Monitoring programme in the area of materials and articles intended to come into contact with food.

PLAC III project expert Raymond O’Rourke presented results of his work at a workshop held in Belgrade on 10 May. He discussed with the representatives of the Ministry of Health the Monitoring programme and presented drafts of two by-laws that are in line with Union acquis – a Rulebook on implementation of the monitoring programme for products of general use and materials and articles intended to come into contact with food for each year in accordance with the risk-based approach and a Guide which will determine the implementation of a Monitoring Programme. Draft Guide included the number of samples and parameters as well as product categories monitored in the internal market and the sources of financing for that purpose in compliance with requirements of the relevant EU acquis.

The Rulebook is intended to complement the efforts of Serbia to align its general product safety monitoring system with requirements of Chapter 28 in relation to kid’s toys, personal hygiene products, facial and body care products, cleaning products, as well as tobacco derivatives

The workshop was attended by the Ministry of Health representatives.

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