Document 7Z2Vb007LzNJZEeL2QMqDX2e

jtusrr -vijtA European 'iSticised PVC Film Manuiacturers Association S*cr*T*rii: Put, Marwick. Mitchall & Co. Ttlwhont: (07427 731234 Tl*x: 54170 Telegram*: Varitatam Shaffiald Ul a 4 Prof. Dr. A. Hildebrandt Bundesgesundheitsamt Postfach 330013 D-1000 Berlin 33 West Germany P. 0. Sox 121. Tha Pountain Precinct, 1 Balm Green, SHEFFIELD. SI 3AF. 10th May, 1985 Dear Professor Hildebrandt, Flexible PVC Sheets We refer to your letter of 21st January, in which you give advance notice of intention to withdraw |he recommendation of flexible PVC sheets for the packaging of frest meat. We would strongly urge you to reconsider this proposal for he following reasons: First, with regard to the allege* disadvantage of PVC in transferring plasticiser to meat. Dr. Rudt h; reported (Hamburg Conference on Migration, November 1983) that tJ :e total migration of plasticiser from this type of wrapping into all f< ids, even with safe assumptions, is only 1.5 gms per person per year) This is obviously a perfectly safe quantity where approved plasticii ers are concerned. Indeed, the Council of Europe's recommendatlj ns (agreed by the German representative) give for such plasticisers sped ic migration limits into food of 60 mg/kg. This is the same 11ml agreed between us and currently incorporated in BGA recommendatlj ins. The migration of plasticisers into meat from PVC films is beloj this figure. Second, we would urge that, whi] other films could be used for wrapping meat, they suffer from lany disadvantages, some of which are listed below: (i) Inferior meat keeping bedause of lower moisture vapour transmission. This in prfactice limits the loading of trays thus increasing cost. (ii) Inferior machinability add costs of adapting packaging machines. (iii) Inferior cling and heat : .eal. (iv) Inferior clarity and ant :.fog properties. (v) Inferior elastic recoverr and puncture resistance. /cont.. SPI-00832 As previously suggested in our discussions, we believe the opinions of the users should be obtained before a final decision is taken. We are enclosing the report froo NATEC, and a covering letter which elaborates on the first point abbve. Third, we draw your attention tol the illogicality of banning one product because another is alleged to be satisfactory, and the undesirability of taking unilateral action at a time when the EEC is working on harmonising legislation. Germany is at present the only Common Market Country proposing a ban on PVC film for meat wrapping. We believe such action would be contrary to Article 30 of the Treaty of Rome (e.g. Cassis de Dijon Judgment). We suggest it would be helpful in resolving these matters for us to have a further meeting. Yours faithfully, Secretaries SPl-00833