An overview of the scientific studies conducted to understand the exposure to kitchen towels and napkins shows that exposure is very low. This result convinced the Council of Europe that the use of kitchen towels and napkins does not pose a risk to the health of consumers.

Scientific studies on exposure and migration

A number of studies were conducted to understand how many kitchen towels and napkins are used in food contact and how they are used. ETS commissioned IPSOS to conduct a multi-national market research survey to understand the extent of food contact to kitchen towels and napkins both in terms of time and quantity

The exposure was found to be very low. Only 27% of kitchen towels and napkins are used in food contact The other 73% are used for other purposes such as wiping and cleaning. On average 1.2 grs kitchen towels is used in food contact per person/day or less than 1/2 of a kitchen towel. Furthermore, most are in contact with food for less than 5 minutes.

The key take-away from these studies is that the amount of tissue paper used in food contact is very limited and short-term.

Indication of use

Regulation (EC) No 1935/2004 on food contact materials provides in Article 15 that materials and articles which are not yet in contact with food when placed on the market shall be accompanied by, among others,

• the words "for food contact", or a specific indication as to their use (…), or the [glass and fork] symbol;

and

• if necessary, special instructions to be observed for safe and appropriate use.

This is without prejudice to more specific labeling requirements. The Regulation applies not only to products that are specifically intended to come into contact with food, but also to products that "can reasonably be expected to be brought into contact with food or to transfer their constituents to food under normal or foreseeable conditions of use". ETS supports the use of the glass and fork pictogram together with the phrases "for wiping" for kitchen towels and napkins to comply with Article 15.

For distribution outside the retail stage, the Regulation allows for the indication to be given in commercial documents. Consequently, and also taking into account the particularities of marketing to "away from home" users, the indication of use can be provided in accompanying documents.

Recycled Fibers and Fluorescent Whitening Agents

Scientific Studies on exposure and migration – The tissue industry uses recycled fiber which potentially contains contaminants. The level of contaminants is either very low or non-detect due to the deinking process prior to use in the tissue manufacturing procedure.

This was confirmed by a series of tests conducted by PIRA Intl. PIRA screened kitchen towels and napkins for typical contaminants in recycled fiber. Most were either below detection limit or not in quantities high enough to conduct migration tests. Hence migration tests were only carried out with 3 contaminants (2 phthalates and diisopropylnaphtalene). Migration was not detectable or very low, in particular when taking into account the conditions of use. CTP conducted a study on fluorescent whitening agents and screened for Stilben derivatives and distyryldiphenyl. CTP did not find any detectable level of migration of fluorescent whitening agents in their study. Therefore, the CoE concluded that the use of recycled fiber and fluorescent whitening agents is safe in kitchen towels and napkins.

Establishment of Migration Test

The CoE requested ETS to establish a tissue specific migration test to be able to assess the exposure to chemicals which are added at a very low level of less than 2%. The test is meant to replicate exposure in real food. To simulate food a semi-solid simulant is used which contains both olive oil and water to mimic both aqueous and fatty food. The migration test for tissue paper is still under development.