Food Contact Compatibility
A subset of ROLL Packaging products is manufactured from virgin HDPE, a material commonly used for direct food contact applications. The product references suitable for food contact use, based on raw material supplier documentation, are listed on this page.
ROLL's position on food contact materials
ROLL SNC di Pini Sergio & C. operates as a downstream user for the raw materials used in the manufacturing of its products. ROLL does not manufacture or import food contact polymers; it purchases finished raw materials (polymers, additives) from upstream suppliers responsible for the conformity of these materials with the applicable food contact legislation.
For the product references listed on this page, ROLL collects from its raw material suppliers a Declaration of Compliance with Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011, available upon customer request for procurement, supplier qualification or audit purposes.
General requirements for food contact materials
Regulation (EC) No 1935/2004 sets out the general principles applicable to materials and articles intended to come into contact with food in the European Union. Under Article 3, food contact materials shall be manufactured in compliance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer their constituents to food in quantities which could:
- endanger human health,
- bring about an unacceptable change in the composition of the food, or
- bring about a deterioration in the organoleptic characteristics of the food.
The raw materials used to manufacture the ROLL product references listed below are supplied with documentation confirming compliance with these general requirements.
Specific requirements for plastic food contact materials
Regulation (EU) No 10/2011 establishes specific requirements for plastic materials and articles intended to come into contact with food, including:
- A Union list of authorised substances that may be used in the manufacture of plastic food contact materials (Annex I)
- Specific Migration Limits (SMLs) for individual substances and an Overall Migration Limit (OML) of 10 mg of constituents per dm² of food contact surface
- Requirements for the Declaration of Compliance issued by the operator placing the material on the market
The virgin HDPE used in the product references listed below is supplied with a Declaration of Compliance issued by the raw material producer, in accordance with Article 15 and Annex IV of Regulation (EU) No 10/2011.
Material origin
Food contact suitability is declared exclusively for products manufactured from virgin polyethylene (HDPE). Products manufactured from recycled polymers, mixed materials, polyurea-coated composites, paper-based materials or steel are not declared as food contact compatible by ROLL, regardless of the technical suitability of the individual material category. Where required for specific food applications, customers are invited to contact ROLL for a case-by-case assessment.
Product references suitable for food contact use
The following 13 product references are manufactured from virgin HDPE and are suitable for food contact use, based on supplier Declarations of Compliance with Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011. The list is grouped by product family.
LO — LOGISTO Roll Cradle Pallets
| SKU | Product | Material | Food contact use |
|---|---|---|---|
| LO01 | Roll Pallet for Floor Handling, 1 to 3 Rolls | HDPE | Suitable |
| LO01C | Roll Pallet for Floor Handling, Custom Color | HDPE | Suitable |
| LO02 | Roll Pallet for Rack Storage, Steel-Reinforced | HDPE + steel bars | Suitable |
| LO02C | Roll Pallet for Rack, Custom Color | HDPE + steel bars | Suitable |
CV — CONVERTO Pallet Transformers
| SKU | Product | Material | Food contact use |
|---|---|---|---|
| CV01 | Roll Converto — Pallet Transformer for Rolls | HDPE | Suitable |
| CV01-C | Roll Converto colored — Pallet Transformer for Rolls | HDPE | Suitable |
| CV01b | Roll Converto — Pallet Transformer for Rolls | HDPE | Suitable |
| CV01b-C | Roll Converto colored — Pallet Transformer for Rolls | HDPE | Suitable |
RM — MODULO Modular Roll Pallets
| SKU | Product | Material | Food contact use |
|---|---|---|---|
| RM01 | High-Strength XS Roll Pallet, Clean Applications | HDPE | Suitable |
| RM02 | Ultra-Strong XL Roll Pallet with 4 Steel Bars | HDPE + 4 steel bars | Suitable |
| RM03 | Long-Format XL Roll Pallet, 3 Modules with Steel Bars | HDPE + 4 steel bars | Suitable |
SO — SOLIDO XL Roll Pallets
| SKU | Product | Material | Food contact use |
|---|---|---|---|
| SO01 | XL Roll Pallet, Price-Efficient Large Format | HDPE | Suitable |
| SO02 | XL Roll Pallet for 1 to 3 Rolls, HDPE Virgin | HDPE | Suitable |
Other ROLL product references
The remaining ROLL product references — including recycled HDPE pallets, recycled PP flanges and wedges, polyurea-coated composite Combo products, STICKO PAPER cardboard cradles and HANGO metal rack stillages — are not declared as food contact compatible by ROLL.
This is a prudential position taken by ROLL regardless of the individual material category, in the absence of a specific food contact Declaration of Compliance covering the finished product. Where required for specific applications, customers are invited to contact ROLL to evaluate the technical and regulatory suitability on a case-by-case basis.
Heavy metals limits also apply to food contact materials
Heavy metals compliance is covered under PPWR Article 5 for all ROLL products.
Regulatory references
This declaration is issued with reference to:
- Regulation (EC) No 1935/2004 of the European Parliament and of the Council of 27 October 2004 on materials and articles intended to come into contact with food, repealing Directives 80/590/EEC and 89/109/EEC
- Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food, as amended
The official text of both regulations in all 24 EU languages is available on the EUR-Lex portal at eur-lex.europa.eu.
Disclaimer
The information on this page is provided for guidance only, on the basis of ROLL's most up-to-date knowledge and experience and of declarations received from its raw material suppliers. ROLL cannot assume liability for damage arising from its use. This statement does not constitute any warranty, express or implied. It is intended only for the addressee and cannot be transferred to third parties. All ROLL products are sold subject to the ROLL SNC general sales conditions. This publication replaces all previous versions and is subject to change without notice.