In 2021, the Finnish Food Authority and Finnish Safety and Chemicals Agency (Tukes) carried out a control project concerning the safety and compliance of children’s plastic water bottles. The control project collected samples of 10 different water bottles intended for children on the basis of their appearance to ensure their compliance with consumer safety legislation and food contact material legislation requirements. Besides the samples, the documents indicating the compliance and traceability of the water bottles were examined.
The water bottles were found to comply with food contact material legislation so far as examined. Based on the results of the random samples in the project, we can assume that the chemical safety of children’s water bottles is at a good level in Finland.
The manufacturer, importer and distributor are responsible for product safety. The authorities do not control products in advance, control is random and risk based.
Tukes oversees the safety of consumer products in Finland. The Finnish Food Authority is responsible for supervising the chemical safety control of food contact materials in Finland. Municipal food inspection units carry out practical control in companies in the food contact material sector in their respective control areas.
Project implementation
In the same context, the municipal food inspection units carried out sampling for both of the authorities referred to above and the control within the remit of the food control authority.
The sampling and controls took place in the spring and summer of 2021. The samples were tested in the Customs Laboratory.
A total of 10 samples were collected. One of the samples was the same water bottle but in two different colours.
- Inex Partners: STOR Car Race Ready 0.4 l water bottle/ Tritan plastic, polypropylene (PP), thermoplastic rubber (TPR), silicone
- Inex Partners: Stor Frozen water bottle 0.48 L / polypropylene (PP)
- Martinex Oy / Muumin characters water bottle 3.5 dl / polypropylene (PP), polyethylene (PE), tritan, silicone
- Tammer Brands Oy / LOL water bottle 400 ml/PCTG
- Tokmanni / Training cup Easy Start 120 ml / polypropylene (PP), polyethylene (PE), silicone
- Lastentarvike Oy / Children’s water bottle, Emma Cup with Strawlid 125 ml, grey / polypropylene (PP), polyethylene (PE), silicone
- Kesko Corporation/ Pirkka baby bottle / polypropylene (PP 05)
- Huntteri Oy Ab / Zefal water bottle 350 ml Little Z / polyethylene (PE)
- Kärkkäinen Web Oy / Zoo Straw Bottle – Unicorn / polypropylene (PP)
- XXL /Contigo Gizmo Flip water bottle / material information unavailable
In addition, compliance documents were examined for the following product:
- A-T Lastenturva /water bottle with straw, 3Sprouts water bottle with straw (350 ml), Fox / polypropylene (PP)
The importer was also asked to provide declarations of compliance for examination and the test results of compliance with the requirements of the Plastic Regulation for the water bottles sampled. In addition the labelling and traceability of the water bottles were examined.
The companies were given access to the inspection report and the control results for the water bottles.
Water bottle control results
All the water bottles intended for young children sampled complied with chemical requirements so far as examined.
The overall migration of substances and the specific migration of Bisphenol A were examined for all water bottles. Examination was conducted in the Customs Laboratory using the method in accordance with CEN/TS 13130-13. The stimulant used was a 3% acetic acid solution and the test condition was contact for 24 h at 40oC.
Plastic food contact material, which water bottles are, must comply with general requirements concerning stability of the chemical composition and with material-specific requirements, overall migration and specific migration limits for individual substances in the Plastic Regulation. Overall migration may not exceed 10 mg/dm2 or in the case of food contact material intended for young children 60 mg/kg. Specific migration limits have been laid down for some substances on the list of authorised monomers, other starting substances and additives in the Plastic Regulation.
Control results
Declarations of compliance
A declaration of compliance, indicating that the plastic material or article complies with the general requirements of the Framework Regulation and the specific requirements of the Plastic Regulation must accompany all stages in the plastic food contact material trade.
The content of the declaration of compliance has been laid down in Annex IV of the Plastic Regulation and guidance is provided in the European Commission’s guidelines on declarations of compliance. The content of declarations of compliance for water bottles was examined in accordance with these guidelines.
Nine declarations of compliance were examined. However, the declarations applied to 10 bottles because samples 1A and 1B were the same bottle but in different colours and so had the same declaration of compliance. The declarations of compliance for two samples were back orders but one of them was submitted and taken into account in examining the content. The content of the declarations of compliance were examined and some shortcomings were found. One declaration of compliance was out of date, being more than seven years old. Finnish Food Authority recommendations are that declarations of compliance are less than three years old because changes in product legislation and probably also in product raw materials have generally already occurred within this timespan.
The figure below shows information concerning the content of declarations of compliance. Most shortcomings were found in notification of the limits of restricted constituents (50% of the declarations of compliance examined). Restricted constituents must always be indicated for plastic food contact materials and confirmation that their migration to food remains below the limits specified in the Plastic Regulation. Where no restricted constituents have been used, this must also be indicated in the declaration of compliance.
In only two declarations of compliance was there an indication of whether or not the water bottle contains dual use substances. Dual use substances are food additives or food flavourings that are also used in the manufacture of food contact materials. If these have been used, this must be indicated in the declaration of compliance. If they have not been used, there is no need to indicate this. The result of the examination does not directly lead to the conclusion that food additives or food flavourings have not been indicated.
Figure 1. Declarations of compliance and their content
Traceability
Traceability is an essential part of the safety of food contact materials. Under the food contact materials Framework Regulation, an operator in the sector must have systems and procedures in place to identify the businesses from and to which materials have been supplied. This means that the manufacturer must know where the materials in the product come from and where the finished products go.
Traceability was implemented as required by legislation in almost all the water bottles. For nine of the water bottles, the company was able to show the delivery documents demonstrating traceability. For eight of the bottles, traceability could be established from the product itself or its labelling. For eight samples, the documents of compliance could also be connected to the product itself. For one water bottle, the information was not completed on the control form.
Guidance for business operators
Advice and guidance were provided in eight examinations and an exhortation in one. No orders were issued. The exhortation was given because the declaration of compliance was missing and this was subsequently provided as a back order.