Advice

technical and legal

Do you need technical-legal advice?

If you belong to the Basque food value chain, Ontzi

offers you a technical support service aimed at resolving technical-legal queries, a service that arises from the need to comply with environmental and food safety requirements attributable to containers and packaging in the food sector.

FAQS


What does the plastic tax apply to?
?

The tax applies to all packaging containing non-reusable plastics brought into Spain. They also include semi-finished plastic products for packaging (sheets, films, preforms) and plastic elements for closing and presentation of goods (caps, closures, labels, etc.).

 

How much is paid?

0.45 per kg of virgin plastic.

  • Recycled plastic is exempt, but supporting documentation must be provided.
  • The tax is effective as of January 2023.
  • If they are destined to other countries, they are outside the scope of the tax.

 

Who should pay this tax?

  • Packaging manufacturers and purchasers who buy packaging or packaged products from other EU countries pay.
    • Payment is made by quarterly self-assessment.
    • If during the quarter the products are shipped outside Spain, the deduction can be claimed.
    • If it has already been paid in a previous period, a refund may be requested. It is important to have documentation to justify it.
  • Importers of containers or packaged products must also pay for such containers, but in accordance with customs regulations.
  • In the manufacturer’s invoices to its customer, the corresponding amount of the tax must be charged and the amount and quantity of non-recycled plastic must be itemized.

 

Who is the manufacturer?

Manufacturing is defined as the elaboration of products subject to this Tax. The production of packaging exclusively from the products is not considered as manufacturing:

  • Semi-finished plastics for packaging (such as preforms or thermoplastic sheets).
  • Products containing plastic intended to enable the closure, marketing or presentation of non-reusable containers.
  • From other products that do not contain plastic.

The incorporation into the packaging of other plastic elements which by themselves, individually, do not form part of the objective scope of the tax, is also considered to be manufacturing. In other words, the tax applies to the entire package, including any plastic component added to it, even if that component alone would not be subject to the tax.

 

Which packaging is exempt from the tax?

  • Packaging, semi-finished or closure/marketing products for drugs, medical devices, etc.
  • Plastic rolls for agricultural or livestock use (fodder or cereal bales).
  • Import or purchase of less than 5kg per month.
  • Semi-finished products or closure/marketing products that are not to be used as packaging.

 

Our products are reusable and would not be affected by this tax. Is any kind of justification necessary? Would the declaration provided by our supplier be sufficient to demonstrate that it is exempt from the tax because it is reusable packaging?

To justify that they are reusable, it is best to comply with the UNE-EN 13429 standard for reuse. The standard evaluates both the design of the packaging and the existence of reuse systems that allow it to be used several times. As long as there is a reconditioning and reuse system in place, there would be no problem in passing the standard.

According to the Ministry of Finance, if the supplier’s declaration is supported by supporting technical documents, it will be valid. We advise that in order to declare that a container is reusable, it must comply with the reusability standard UNE-EN 13429. The Tax Agency states that compliance with this rule exempts them from paying the tax.

 

If the packaging is removed at the importer’s premises (e.g. shrink-wrap), and it is not shipped to a subsequent customer. Would it fall within the scope of the tax?

The tax applies since the packaging is being introduced in the Spanish market, even if it is later removed once the goods arrive at the facilities of any company, it is understood that this film has been used. Once the film is introduced into the Spanish market, as importers it is necessary to pay the tax on the proportion of plastic introduced with the corresponding SAD.

 

Do compostable section bags pay tax?

Compostable bags, as well as other compostable plastic packaging, as long as they are intended to be packaging (which is the case of section bags), will have to pay the tax for not being reusable and for the virgin content they contain (which will be 100%).

 


What is the Extended Producer Responsibility Regime (EPR)?

It is the set of measures taken to ensure that product producers assume financial and/or organizational responsibility for the management of the waste phase of a product’s life cycle.

 

How can I register as a product producer with the Ministry?

You can register as a product producer online through the MITECO website in the Product Producers Registry section, for which you must have electronic identification(Procedure Sheet – MITECO Electronic Office).

 

Where can I make the packaging declaration with respect to the new Royal Decree 1055/2022 on packaging and packaging waste?

Through the MITECO website you can annually submit the quantities in weight by type of material of the packaging you place on the market, differentiating whether they are single-use or reusable, according to the options included in the Register of Producers.

 

Do we need to be adhered to a system of extended responsibility (SRAP)?

At the time of registration, it is necessary to provide a certificate of membership in an individual or collective extended producer responsibility system. However, there is a two-year period to set up extended producer responsibility systems (individual-SIRAP or collective-SCRAP) for industrial and commercial packaging, and until they are set up it is not necessary to provide a certificate of membership. Once constituted, the maximum term is one month to submit it to the Registry.

 

Who provides the Extended Producer Responsibility System service? Where can I consult the SRAPs already authorized?

In the case of a SIRAP (Extended Individual Producer Responsibility System), the company itself is responsible for managing the packaging once it has reached the end of its life. This involves paying for and organizing all waste collection and proper treatment.

On the other hand, the SCRAP (Collective System of Extended Producer Responsibility), are under development, but these are some of the existing ones: ENVALORA, CIRCULAR CARTON, IMPLICA, PROCIRCULAR, RECYCLIA, ECOLEC ENVASES, GENCI, GRETA.

In general, all the authorized SRAPs can be consulted in an updated manner at the following web link of the Ministry for Ecological Transition and the Demographic Challenge: https://www.miteco.gob.es/en/calidad-y-evaluacion-ambiental/temas/prevencion-y-gestion-residuos/flujos/responsabilidad-ampliada.html#envases-ligeros-y-papel-carton

 


When is packaging considered recyclable?

A package is considered recyclable if it has effective recyclability of packaging waste, which is determined by considering the following criteria:

  • That it can be collected separately in an efficient manner, through user access to nearby collection points;
  • That it does not present characteristics, elements or substances that impede its classification and separation, its recycling or limit the subsequent use of the recycled material;
  • That they are recycled on an industrial scale with commercial processes that guarantee sufficient quality of the recycled material for subsequent uses, and in a quantity greater than 50% of the mass of the waste collected from that type of packaging;

 

How can I prove that my packaging is recyclable?

To determine that a container is recyclable, it is best to comply with the UNE-EN 13430 recyclability standard. This standard specifies the requirements that packaging must meet in order to be recyclable. Evaluates taking into account design, production, utilization, collection and classification criteria.

 

Is it mandatory to mark the packaging as recyclable?

The recyclability marking of a container is not mandatory. The “recyclable” marking is a self-declaration, but needs to be supported by an external entity. In fact, if you wish to include the percentage, it is mandatory to have technical documentation issued by an external party.

However, it is mandatory from 2025 to indicate the fraction or container in which to deposit household packaging waste at the end of its useful life.

 

We have containers of more than one material (cardboard and plastic) that need to be separated for proper recycling, but there may be paper residues on the plastic, is there any percentage of paper that can be stuck to the plastic so that it does not influence its recyclability and can be thrown into the yellow container without being penalized by the new legislation?

There is not really a stipulated amount of what is the maximum amount of residue that should remain after separation of the components, but it could be defined as 5%, which is the figure indicated by CENT/TR 13688 as the limit for the content of non-plastic materials in a structure.

 

What happens if I am a converter and my scrap (for example, from a reel that was 80% recycled 20% virgin PET) is sent to a certified supplier who uses it to generate new inputs (sheet)?

If the scrap is sent to a recycler who processes it, it could be counted as recycling. However, this process must be certified by an accredited entity under the UNE-EN15343 standard.

 


What is considered reusable packaging?

A package is considered to be reusable when it has been conceived, designed or introduced into the market for multiple circuits or rotations throughout its life cycle, being refilled or reused for the same purpose for which it was conceived. For example, an empty drum that is subsequently filled by a customer, who then returns the empty drum to the supplier for conditioning and the supplier returns it to the customer again after conditioning.

 

How do I determine that my container is reusable? How do you prove if it is reusable packaging, because the manufacturer marks it on the package or because the customer reuses it?

To determine that a container is reusable, it is best to comply with the UNE-EN 13429 reusability standard. This standard evaluates both the design of the packaging and the reuse systems that allow it to be used several times.

A package is reusable when there is a reuse system in place in the marketing territory. Therefore, the manufacturer has to design packaging that can withstand several cycles of use and the distribution and reconditioning cycle, and the customer has to reuse it.

 

Do reusable containers have to be marked on the packaging by law? If they are not marked, it is not considered reusable, even if the customer gives it a second use?

According to Royal Decree 1055/2022 on packaging, reusable packaging must indicate its reusable condition as of 2025, and the symbol associated with the deposit, return and refund system.

 

What are the requirements for reusable packaging? Is there a list of reusable packaging requirements or details?

The UNE-EN 13429 reuse standard establishes the necessary criteria for reuse:

  • Deliberate objective
  • Adequate design
  • Reconditioning system adapted to the container
  • Reuse system implemented in the market

 

If a container is reusable, is itIf a container is reusable, is it mandatory that it must be adhered to a Return, Deposit and Return System (DRS)?

It depends on the reuse system in place. All reusable packaging must adhere to a DRS except for household packaging whose reuse system relies on the refilling of the container by the user or consumer through products packaged in single-use containers.

 


We are a manufacturer of empty containers that we sell to our customer and our customer also sells them empty, and so on. Empty containers are delivered to the end customer and filled according to their needs. Would these items count as packaging?

These bottles are considered containers because they are designed to contain, protect, handle, distribute and present goods regardless of whether you sell them empty or full. Therefore, the tax applies to them.

 

Is it mandatory to print the Ecoembes Green Dot on packaging? What is the timing with respect to this icon? Is it mandatory to put another icon?

Printing the ECOEMBES GREEN DOT on packaging is not mandatory, but it serves to demonstrate that packaging companies comply with the obligation to ensure the proper management of household packaging, participating in the packaging waste management model managed by Ecoembes.

From 2025, it will be mandatory for household packaging to indicate the fraction or container in which it should be deposited. In the case of compostable packaging, the label must state that it is certified according to the harmonized standard UNE-EN 13432. Reusable packaging shall indicate its reusable status, and the symbol associated with the deposit, return and refund system (DRS).

 

Is it mandatory to include the “BIO” logo for our packaging?

Current legislation does not regulate the marking of “Bio Based” packaging. The “BIO” logo is a self-declaration of the percentage of material of biological origin contained in the packaging. This information must be supported by technical data, for example, in the technical data sheet of the package.

 

If my packaging is compostable, do I have to add the logo?

Compostable packaging in home or industrial composting will be required to include the message “do not leave in the environment” from January 2025. They must also report that they comply with UNE 13432:2001 certification or other European and national standards on plastic compostability under industrial conditions or biodegradation through domestic and community composting.

 

Is it mandatory to mark the type of packaging material and the percentage of recycled material?

Packaging may be marked with the percentage of packaging material, including its components, available for quality recycling on a voluntary basis. This percentage can only be indicated if it has been obtained through an auditable and certifiable evaluation by entities other than the packaging manufacturers and the product producers themselves, taking into account the characteristics and the collection, sorting and recycling technologies existing on an industrial scale at the time the product is placed on the market. This percentage must be reviewed at least every five years.

In relation to the content of recycled material, containers may (voluntarily) be marked indicating the percentage of recycled material they contain, provided that the documentation accrediting such percentage is available (reference standard UNE-EN 15343).

 

 

How often must the declaration of conformity be updated?

When modifications are made to the composition of the material or new transformations (thermoforming, printing, etc.).

When new amendments to Regulations or legislative developments are published that directly affect my packaging material.

For good manufacturing practices, it is advisable to review the information included in the Declarations of Conformity every 2 years or as required by the customer.

 

Is it known if specific migration regulations are being created for compostable materials?

To the best of our knowledge, there are no norms or standards for the realization of migrations in compostable materials. The standards available do not refer to the type of plastic. Specific purity requirements for biomaterials are expected to be added in future amendments to Rg 10/2011.

 

Regarding migration tests, can different results be obtained depending on the contact method applied? In other words, is the definition of the contact method decisive if several can be applied?

The result should be the same, (the surface area that is in contact with the simulant volume is taken into account). However, it is possible that when total immersion is used it is superior, since the entire material is immersed in the simulant and therefore twice the area would be exposed to the simulant compared to one-sided contact. Therefore, whenever possible and if the expected contact is one-sided, we will use one-sided contact methods, reserving total immersion for those geometries where one-sided contact is unfeasible.

 

Which food simulant is recommended for a NIAS screening for fatty foods? And to cover all types of food?

For fats, simulant D2 would be appropriate, but we recommend using the fatty alternatives 95% ethanol and isooctane, since the determination in oil is complex. The determination in oil goes through a solvent extraction, prior to injection into the equipment. For this reason, it will be unfeasible to know with certainty whether all the compounds that the oil extracts from the material are extracted by the solvent of choice and analyzed in the instrument, and sometimes, during the solvent extraction stage, emulsions are produced that are difficult to break up, making it difficult to extract the substances. NIAS are unknown substances, if we do not know what is there we do not know how to extract it from the oil or in what quantity we are going to extract it.

The use of A, B and D2 (alternative) simulants is recommended to cover all types of food.

 

When technical data sheets are submitted, especially for plastics, is it regulated that the declaration of conformity is backdated at any point in the regulations?

The plastics regulation establishes that the information related to the suitability for food contact must be transmitted by means of the DECLARATION OF CONFORMITY, which is also regulated by the regulation itself, in Article 15 and Annex IV, the latter containing the requirements as regards content. One of the requirements established for the content of the declaration is the date of the declaration. But it does not give any indication of the date of other documents, such as technical data sheets.

 


Taking into account Regulation (EC) No. 1616/2022. Does the Declaration of Conformity Annex III have to be provided to me by the supplier that only thermoforms to make trays from a sheet that includes a % of recycled plastic or does it only apply to the converter that makes the sheet and therefore the one that uses the recycled material?

The Declaration of Conformity Part A applies to the recycler only. Part B to the successive transformers of the recycled material; therefore, both the manufacturer of the sheet and the thermoformer of the trays will have to issue their Declaration of Conformity in accordance with the template of Part B; and on the basis of the information obtained upstream.

 

Does the transformer’s declaration of conformity for a bottle made from recycled plastic have to be made by batch?

The lot number must be updated in each Declaration of Conformity, even if the rest of the information to be provided is the same.

 

If the packaging is made from production trimmings, can it be said to contain recycled plastic?

These requirements will be included in amendment 17 of Rg 10/2011. At present, the reprocessing of trimmings, unless it is carried out using a suitable or new technology, is not covered by the legislation on materials and articles intended for food contact.

 

What is called chemical recycling in this regulation?

In the past, EU legislation on recycled food contact plastics excluded several manufacturing technologies from its scope. This is no longer the case. All plastic food contact materials containing plastic from or manufactured from waste are subject to this Regulation, even when they are produced using a chemical recycling technology instead of a mechanical recycling technology. These chemical recycling technologies break down the plastic to a certain extent.

The new Recycling Regulation only excludes from its scope the use of waste to manufacture substances included in the Union list of authorized substances in accordance with Article 5 of Regulation (EU) No. 10/2011 on food contact plastics. The substances manufactured must be used in full compliance with this Regulation and may not contain oligomers or contaminants from waste.

In other words, if the chemical recycling process is used to obtain starting monomers or additives listed in Annex I of Regulation (EU) No. 10/2011, these would be subject to this single Regulation. On the other hand, if these technologies break down the plastic into dimers or simpler polymers, they would fall within the scope of the Recycled Plastics Regulation.

 

What requirements apply to recycled plasticsWhat requirements apply to recycled plastics from outside EU territories to be placed on the EU market?

The same standards apply to all plastics marketed in the EU.

This means that a recycling facility located outside the EU must fully comply with the new Regulation if it manufactures recycled plastic that is placed on the EU market.

Similarly, if plastic materials not yet decontaminated are imported into the EU and are to be used as an input to manufacture recycled plastic for food contact in the EU, they must comply with the same rules on origin, collection methods and quality control applicable to material collected in the EU.

The use of A, B and D2 (alternative) simulants is recommended to cover all types of food.

 

Is the packer of a foodstuff that uses packaging with a certain percentage of recycled material also obliged to issue a declaration of conformity in accordance with the model set out in the new Regulation?

The packer, unless he is manufacturing/transforming such packaging material (e.g. blowing bottles from a proforma) would not be obliged to issue such DoC, he may use the DoC of his packaging supplier (which should comply with Annex III template B).

 

In the case of plastic materials used to package packaging materials that will be in contact with food (e.g. shrink wrap film). What are the risks and requirements for this type of material?

Such material, if it is not expected to end up in contact with food, would not fall under the scope of the new Regulation on recycled plastics for food contact, so it would have to be treated like any other industrial secondary packaging.

 


I have a query about BfR XXXVI, the control of BPA or phthalates for paper and board, would it be controlled only for recycled papers? If it is a virgin paper, isn’t it?

These compounds are usually present due to the use of recycled fibers (because they are contaminants themselves, due to ink residues…), so this analysis is not required for virgin paper.

 

Is it always necessary to perform migration testing to make the claim?

It is not strictly mandatory. The performance of migration tests depends on where we are in the supply chain, and will also depend on the information provided by the suppliers, the composition of the material, etc…

 

If the converter requests a NIAS-free declaration from a paper supplier, to what extent is the paper manufacturer obliged to test for NIAS migration? Or should you request it from your raw material supplier? Due to the high cost of these tests, there is a possibility that no one in the supply chain will perform the tests.

NIAS can appear in any part of the supply chain, in fact, part of these substances can come from impurities in the raw materials used, but another fraction of NIAS can come from reactions between components, from the degradation of components or from contamination (among others), processes that can take place during the manufacture of the final article. Therefore, a priori, no link in the food contact materials supply chain can be ruled out.

The processor can be certain (because he is told by his raw material suppliers) that the materials he uses are free of NIAS, however, during the processing and storage of the final goods, new NIAS may appear.

 

Is there French legislation regulating the presence of MOSH/MOAH in packaging? What limits? Is it in force?

That’s right, Decree No. 2020-105 on the ‘Fight Against Waste and the Circular Economy, which:

  • It bans mineral oils in packaging as of January 1, 2022.
  • Prohibits mineral oils in printing intended for the general public as of January 1, 2025. This ban, however, will come into effect on January 1, 2023 for unsolicited advertising materials and catalogs for commercial promotions.

On May 3, 2022, the French Ministry of Ecological Transition (Ministère de la Transition écologique) published the Decree of April 13, 2022 (Arrêté du 13 avril 2022, the Decree) to regulate two categories of mineral oils and their requirements for the application of Articles D543-45-1 and D543-213, as well as Decree No. 2020-1725. The Decree contains several important provisions. First:

  • Delays the effective date of Article 112 of Executive Order No. 2020-105 from January 1, 2022 to January 1, 2023.
  • Defines mineral oils as oils produced from raw materials derived from petroleum hydrocarbons used in the production of inks. It provides a specific definition for mineral oils and specifies their ink requirements. It is in these requirements that these limits are included.
  • Indicates that conformity can be checked before or after application or printing.

 

Is there French legislation regulating the presence of MOSH/MOAH in packaging? What limits? Is it in force?

 

There is no batch-to-batch uniformity of NIAS in recycled fibers. Does each batch have to be analyzed?

Since it is not feasible to analyze every lot, one recommendation is to establish a reasonable initial frequency of analysis based on suppliers, external factors (such as customer requirements, changes in legislation, changes in processes, etc.). This analysis scheme can be established according to the probability of exceeding restrictions or limits. It should be established on a statistical basis.

Depending on the results over 1 year, for example, it can be evaluated whether it is possible to decrease this frequency.

According to CEPI’s GMP guidance, regarding frequency of testing (but not specifically NIAS): “In addition, an end-product testing scheme should be considered, to comply with legislative and customer specifications. Therefore, analyses should be carried out at a frequency related to the probability that a specific restriction or limit may be exceeded. This frequency should have a demonstrable statistical basis and will depend on a number of factors, e.g. raw material variability, process variability and testing accuracy. In certain cases, it may be necessary to align the frequency with external factors, such as customer requirements and Statements of Compliance. Once the initial frequency has been determined, the risk assessment that determined that frequency should be reviewed at least every twelve months. However, if it can be demonstrated by e.g. calculations, by knowledge of constituents, or by other information that has conclusive weight, that a particular substance could never exceed its limit in the material or object, the facts should be documented and it may not be necessary to conduct testing of that substance.”

 


Regarding inks, must they be suitable for food contact or can “conventional” inks be used and the packaging manufacturer verify that the ink does not migrate into the food?

The inks, from the outset, should be suitable insofar as substances that do not pose a health risk have been used in their formulation. It’s not just migration. In the formulation itself, when the ink is “suitable”, it does not normally contain carcinogenic, reproductive toxic, mutagenic, etc. substances.

It is true that there are no harmonized measures at the European level, but, for example, Swiss legislation establishes a positive list of substances that may be used in their manufacture. In addition, EuPIA, the European association of printing ink manufacturers, has published numerous documents aimed at providing guidance to food contact ink manufacturers and printers. Their recommendations range from the correct formulation to how to evaluate the migration of ink components.

 

Does BfR Recommendation XXV on kerosenes and microcrystalline waxes also consider the possible migration of these compounds into food or only the composition and purity of the compounds to be used in the formulations?

Recommendation BfR XXV. Hard Paraffins, Microcrystalline Waxes and Mixtures of these with Waxes, Resins and Plastics, marks requirements of composition of this type of formulations, viscosity and purity. The restrictions that exist are more related to the maximum content of certain substances, which must be validated at the formulation level, not so much in the final article.

 

Regulation (EC) No. 2023/2006 states that The printed surface of a package must not come into direct contact with food. how should I interpret direct contact? Can it be done with a varnish? accidental contact is allowed?

Direct contact refers to the printing ink being the layer that is directly in contact with the food, without any varnish, laminate, or any other type of material getting in the way of such contact. If the contact is accidental, it would not be working in accordance with good manufacturing practices, since the use is not associated with direct contact with the food.

According to EuPIA, FCM inks are designed and formulated for use on the non-food contact surface or on the food contact surface of materials and articles intended to come into contact with food, and are clearly specified with respect to their use as “FCM ink” or “direct food contact printing ink” (DFC ink, a subgroup of FCM inks), respectively. Although, as noted for food contact applications intended for prolonged storage or fatty and moist foods, the use of overprint varnishes is recommended.

 

Currently there is talk of “oil coated” treatments on paper and paperboard that improve the resistance of the paperboard to aqueous or fatty products. These products would be considered varnishes/coatings. Exactly what documentation do we have to request from suppliers of these substances to check whether they comply with legislation for use in packaging or products that will come into contact with foodstuffs?

A Declaration of Conformity (DoC) or equivalent document must be requested from them, where the supplier in question states which legislation the coating complies with, if there are any restrictions on use, etc. The content of this DoC is not legislated, as there is no specific harmonized legislation, but it may be similar to what we have seen in the class.

As explained in the course, the coating must comply with the framework regulation and be manufactured according to good manufacturing practices. In addition, a reference legislation should be chosen to comply with the safety principle of the framework regulation. Compliance with RD 847/2011, which applies to coatings marketed in Spain, is recommended. In this regard, a list of substances that may be used in the manufacture of the coating is included, and it is also permitted to use substances listed in Regulation (EU) No. 10/2011 and other national legislation of Member States.

It is advisable to respect the conditions of use given by the coating supplier in terms of application and grammages, because they are normally designed to comply with the legislation.

 

Currently there is talk of “oil coated” treatments on paper and paperboard that improve the resistance of the paperboard to aqueous or fatty products. These products would be considered varnishes/coatings. Exactly what documentation do we have to request from suppliers of these substances to check whether they comply with legislation for use in packaging or products that will come into contact with foodstuffs?

A Declaration of Conformity (DoC) or equivalent document must be requested from them, where the supplier in question states which legislation the coating complies with, if there are any restrictions on use, etc. The content of this DoC is not legislated, as there is no specific harmonized legislation, but it may be similar to what we have seen in the class.

As explained in the course, the coating must comply with the framework regulation and be manufactured according to good manufacturing practices. In addition, a reference legislation should be chosen to comply with the safety principle of the framework regulation. Compliance with RD 847/2011, which applies to coatings marketed in Spain, is recommended. In this regard, a list of substances that may be used in the manufacture of the coating is included, and it is also permitted to use substances listed in Regulation (EU) No. 10/2011 and other national legislation of Member States.

It is advisable to respect the conditions of use given by the coating supplier in terms of application and grammages, because they are normally designed to comply with the legislation.

 

I wanted to confirm: adhesives (indirect food contact) at the documentation level, is the Declaration of Conformity also mandatory? Is there a standard document or does each company create its own document?

Adhesives are materials for which there is currently no harmonized legislation. Likewise, and according to Article 16 of the Framework Regulation (EC) No. 1935/2004, for materials without this type of legislation, a similar document declaring their suitability for food contact, as well as the use for which they are intended, is required. The most common for adhesives is based on the documents published by the FEICA association, and in particular the one referring to the declaration of conformity. This document is not a standard as such, but it does indicate the information that should be present.

 

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