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Hazel
O'Keeffe
Partner
Brussels
Hazel O'Keeffe
©2024 Keller and Heckman LLP

Hazel O'Keeffe counsels clients on the regulation of food contact materials, notably in the European Union (EU), Switzerland, and the United Kingdom, focusing on establishing a suitable status for all types of food contact materials at both the EU and national level. Hazel helps clients navigate the complexities of applying the principle of mutual recognition to facilitate the free movement of non-harmonized products throughout the EU, the European Economic Area (EEA), and the European Free Trade Association (EFTA) countries. 

Hazel also has a strong sustainability/environmental practice focusing on packaging waste, extended producer responsibility schemes, single-use plastics, plastic taxes, biocides, the substantiation of green claims, recycling, fluorinated greenhouse gases, and ozone-depleting substances.    
                          
She also advises on inter alia, materials in contact with drinking water, personal protective equipment, medicinal products/European Pharmacopoeia, medical devices, cosmetics, and horizontal issues such as product safety and liability. 

She completed an internship at the European Commission, during which she focused on relations with the European Parliament and gained first-hand experience of the workings of the EU institutions.

Hazel is a contributing author to packaginglaw.com, as well as related industry publications, and is frequently invited to speak at international conferences.

Representative Matters

  • Evaluated the EU status of food contact materials (including plastics and non-harmonized materials such as rubber, silicones, adhesives, paper, and printing inks) and drafted legal opinions documenting conclusions; assisted with the wording of EU food contact Declarations of Compliance (DoC)
  • Submitted numerous petition dossiers for food contact substances to the European Food Safety Authority (EFSA), including in novel areas such as active packaging and nanomaterials, and to national authorities such as the German Institute for Risk Assessment (BfR), the Dutch G4 Commission, and the UK Food Standards Agency
  • Advised on the Recycled Plastics Regulation (EU) 2022/1616 requirements for suitable and novel technologies and assisted non-EU companies in locating a competent authority
  • Advised on divergent national requirements for materials in contact with food and drinking water and how the mutual recognition principle may be used to facilitate the free movement of goods throughout the EU  
  • Advised on national requirements for materials in contact with drinking water and on the developments regarding an EU positive list of substances; petitioned new substance intended for use in drinking water applications to the German Environment Agency (UBA)
  • Successfully handled data sharing negotiations for memberships of substantive consortia and advised on issues related to treated articles and biocidal products (including public health claims) under the EU’s Biocidal Products Regulation (BPR), as well as the interplay between the BPR and other legislation, such as the food contact materials legislation
  • Advised on green claims such as recyclable, recycled content, compostable, and climate-related data required to substantiate green claims as well as the evolving EU regulatory landscape; advised regarding the wording of Environmental, Social and Governance policies and commitments
  • Advised on obligations arising under national Extended Producer Responsibility schemes, notably in the food packaging area, in both the EU and the UK 
  • Advised on recalls and withdrawals of products from the EU market, notifications pursuant to RASFF (the EU’s Rapid Alert System for Food and Feed), and Rapex (Rapid Alert System for Non-Food Products), and non-compliance issues for products more generally
  • Advised on Brexit-related matters

Memberships

  • British Chamber of Commerce in Belgium

Education

University College, Cork, Ireland, 1996 Bachelor of Civil Law Degree
University of Limerick, Ireland, M.A., 1998 European Integration
Incorporated Law Society of Ireland, 2003 Solicitor