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News | German BfR updates some food contact recommendations - silicone, paper, high temperature resistant coatings!

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LCS

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Post time:

2024-08-22

The German Federal Institute for Risk Assessment (BfR) is a scientific institution that undertakes the task of assessing risks, identifying new health risks, developing risk minimization recommendations, and providing policy recommendations without being influenced by economic, political, or social interests. The scope of work includes food, feed, food contact materials, etc.

On August 1, 2024, BfR updated the recommendations for silicone, paper (including food contact paper, cooking paper, hot filter paper, baking paper, etc.), and high-temperature resistant coating food contact. The updated recommendations will take effect from the date of publication.

The updated proposal numbers are as follows:

number name

XV

silica gel

XXXVI

Paper for food contact

XXXVI/1

Cooking paper, hot filter paper, and filter paper

XXXVI/2

Baking paper and cardboard

LI

High temperature resistant polymer coating system for frying, cooking, and baking utensils

The main updates to the requirements and testing methods for this indicator are as follows:

Serial Number Number and Name UPDATE

1

BfR Recommendation XV-silica gel

1. Modify the testing conditions for volatile organic compounds: Products that cannot withstand high temperatures should be tested according to Table 3 of Appendix V of (EU) No 10/2011. The testing conditions for this test item in the old version were fixed at 200 ℃ for 4 hours.
2. Remove the requirement that the extractable content of silica gel in water, 3% acetic acid, and 10% ethanol should be less than 0.5%.

2

BfR Recommendation XXXVI-Paper used in food contact

1. Paper products have mainly updated the requirements for raw materials such as adhesives, preservatives, and wet strength agents.

2. The migration limit of plasticizers has changed:

DEHP migration limit: reduced from 1.5mg/kg to 0.6mg/kg

DBP migration limit: reduced from 0.3mg/kg to 0.12mg/kg

DIBP migration limit: reduced from 0.3mg/kg to 0.15mg/kg

The total migration limit for DBP+DEHP+DIBP is 0.6mg/kg (using the formula Ʃ=DBPx5+DIBPx4+DEHP x1, calculated as DEHP), which is slightly different from the calculation in the EU plastic regulations.

3

BfR Recommendation LI-High temperature resistant polymer coating system for frying, cooking, and baking utensils

1. Add a total migration limit of 10mg/dm2, with testing conditions of 95% ethanol (60 ℃, 6h) and isooctane analog (60 ℃, 4h).
2. Add metal substrate requirements and test according to the latest EDQM requirements. For relevant content, please refer to the previous article 'EU releases the second edition of the Guidelines for Metals and Alloys in Food Contact Materials';

3. Modify the testing conditions for specific migration amounts, remove the old version of the testing conditions, and modify the testing conditions to the testing conditions FPU/H2, FPU/H3, and FPU/H4 corresponding to plastics in the JRC guidelines "Testing Conditions for Kitchen Utensils in Food Contact: Plastic, Metal, Silicone Rubber and Rubber, Paper and Paperboard". One exception is that the testing time for FPU/H4 has been reduced from 8 hours to 4 hours. Because the migration of 3% acetic acid for 8 hours may cause corrosion of the object, which is an uncommon phenomenon in practical applications. The dry analog MPPO test is revised to DIN EN 14338, with a test condition of 175 ℃ for 2 hours;

Note: Specific migration tests were conducted three times on the same sample, using different food simulants each time. Compliance judgment shall be based on the results of the third test. For substances that cannot be detected within a specific migration limit, they must comply with that migration limit in the first test. This paragraph requires clarification on compliance determination, and coating products do not need to undergo three trend determinations in accordance with the EU Plastic Amendment Directive EU 2020/1245.

LCS suggestion:

Although the BfR proposal does not have legal binding force, it has been widely recognized by the industry and has become an important reference for products entering the German market. It is recommended that relevant enterprises pay attention to the updated content and do a good job in compliance work for related products as soon as possible.

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