Safety and Suitability of Ecoffee Cup
I am writing to reassure you as to the safety and suitability of Ecoffee Cup for its desired purpose – namely, daily re-use with drinks at temperatures up to +100C˚
Rigorous Testing and Compliance
The importation and sale of Ecoffee Cup has always been governed by European food contact regulations (EC) No.1935/ 2004 and (EC) No. 10/ 2011. Since we started in 2014, we have regularly provided our products to independent test houses such as TÜV Rheinland, SGS and Intertek to ensure compliance with these regulations.
Removal of Melamine
In early 2019, as part of our on-going product improvement cycle, we removed over 80% of melamine from our formulation – reducing it from 25% to <3%. This has been independently verified through pyrolysis testing conducted by Intertek, UK.
Since this formulation change, M-F migration rates have consistently been verified at Not Detected (“ND”) levels. We have also conducted several other tests to ensure suitability of Ecoffee Cup for daily usage to +100˚C; as well as for dishwasher-use and microwave-reheat, well above what is required by the legislation.
Usage of Bamboo
Under EU legislation (EC) No. 1935/ 2004 Articles 9-11, Wood pulp, wood flour, untreated (FCM No. 96) is named as a permitted food contact material. Based on its general properties and almost identical genetic structure (cellulose, hemi-cellulose and lignin), bamboo fibre has been tacitly accepted as “wood” by regulatory authorities. Whilst not "specifically named" as such, since 2014 we have had not one question raised by EFSA as to the efficacy of this interpretation.
Changes to EU interpretation of bamboo as permitted additive
In 2019 an EC Working Group, appointed to examine and report on non-compliant and poor-quality imitation products available in the European market (an objective with which we whole heartedly agreed), made a series of recommendations. Whilst we had addressed most of the group's recommendations prior to their publication, their reclassification of bamboo as a grass, rather than wood, (and therefore not a permitted food contact material) was the change that has affected Ecoffee Cup. Whilst we categorically disagree with this change, we understand that we must comply with regulations required of us.
Change in Formulation and Compliance Testing
In order to ensure Ecoffee Cup is fully compliant with this new, less inclusive interpretation of FCM No. 96, we have replaced bamboo fibre with FSC wood fibre. From a product perspective this makes no physical difference, and we are pleased to confirm that it has exceeded all risk assessment tests required of it, as well as our own regime of rigid testing.
We hope this clarifies the current circumstances and reassures you that, as market leader in this space, we guarantee the quality and compliance of every Ecoffee Cup we produce. We remain open, transparent and available to answer any further questions you may have in relation to these issues.