How sustainable is bamboo tableware?

In the context of "Planet Plastic," banning this material is becoming increasingly popular. In addition to the European ban on disposable plastic products by 2021 (the Single Use Plastic Directive), we also see this trend reflected in the purchasing behavior of consumers. They are increasingly focused on sustainable alternatives to plastic products, both from an environmental and safety perspective. The supply of food contact materials such as dinnerware, mugs, lunch boxes and coffee cups made from organic materials such as bamboo and corn is increasing. But how sustainable and responsible are these products really?

Practical evidence shows that many "bamboo" products consist mainly of melamine resin combined with a small amount of bamboo fibers. The increasing number of notifications regarding the migration of melamine and formaldehyde from such products, misleading marketing and the use of unauthorized substances have attracted the attention of authorities, market regulators and other stakeholders.

The use of melamine in 'bamboo' dinnerware

Bamboo melamine consists mainly of melamine resin, this resin ensures the correct shape and hardness of the final product. The bamboo fibers are only added to give the material structure and thus the desired look and feel. This makes these products considered plastic food contact materials and must comply with the provisions of Regulation EU 10/2011. The specific migration of melamine and formaldehyde, among others, from melamine products must not exceed the established specific migration limits.

The European Rapid Alert System for Food and Feed (RASFF) notification system is already reporting more notifications about unsafe products within this category in the first six months of 2019 than in all of 2018. The most common notifications relate to excessive migration of melamine and formaldehyde. Other stakeholders, such as German consumer magazine Stiftung Warentest, are also reporting the same findings.

Misleading labeling and marketing

There are concerns about misleading labeling and marketing regarding bamboo melamine products. These are commonly touted as being "sustainable," "biodegradable," "natural" and "environmentally friendly. In many cases, the trade name and product description are also used for such marketing, so the products are not perceived by consumers as plastic.

Framework Regulation EC 1935/2004 states, "the labeling, advertising and presentation of a material or article shall not mislead the consumer." Market participants should therefore ensure that labeling and marketing are consistent with the actual composition of the product. In cases where melamine or other plastics are the main component of a material or product, promotional statements implying that the products are made from natural materials or do not contain plastics are misleading and in violation of Article 3 of Framework Regulation EC 1935/2004.

What does the European Commission think?

The recently published summary of the European Commission's Expert Working Group on Food Contact Materials notes that bamboo powder and fibers are not explicitly mentioned in the list of permitted substances. FCM substance number 96 includes "wood flour and fiber, untreated. However, it is questionable whether bamboo as a grass species can be included under this description. The European Commission has asked the European Food Safety Authority (EFSA) to review FCM substance number 96. EFSA's report on this is expected in December 2019.

Do you sell bamboo-melamine food contact materials on the European market? If so, it is important that you have a clear picture of the raw materials used in your product. Based on this, you can determine which migration limits apply and make a clear assessment regarding the statements of marketing claims on and about your product.

Need support?

Do you want to know how to ensure that your food contact materials meet legal requirements? Are you wondering if you can sell your product as a bamboo product? Précon Quality Services can help you with this. Contact us at +31 (0)30 - 65 66 010 or info@precongroup.com. You will receive our free quote.