Food Contact: Germany - Latest Version of BFR Recommendations

On August 1, 2024, the German Federal Institute for Risk Assessment has released the latest version of the BfR (Bundesinstitut für Risikobewertung) Recommendations on Food Contact Materials.

This latest version of BfR Recommendations on Food Contact Materials provides the following changes:

• Recommendation XV on 'Silicones'
• Recommendation XXXVI on 'Paper and board for food contact'
• Recommendation XXXVI/1 on ‘Cooking paper, hot filter paper and filter layers
• Recommendation XXXXI/2 on ‘Paper and paperboard for baking purposes’
• Recommendation LI on ‘Temperature-resistant coating systems made of polymers for frying, cooking and baking equipment’

Insights on the latest version of BFR Recommendations

This latest version of BFR Recommendations on Food Contact Materials provides the following changes:

• Recommendation XV on Silicones: deletes the requirement for extractable component (see Section III, 5 of the document), provides a test method for articles that do not withstand thermal testing which shall be tested according to the temperature/time conditions specified in Table 3 in Annex V of Regulation (EU) No 10/2011, and emphasizes the application of the test method on materials or articles with plastic or textiles such as conveyor belts, coated textiles or two-component injection molded parts for seals (see footnote 16 of the document).
• Recommendation XXXVI on Paper and Board for Food Contact: expands the number of sizing agents (Section BI), retention agents (see Section B, III), preservatives by including sodium benzoate (Section B, VIII), wet-strength agents by including polyvinyl alcohol (PVA, Section C, I) and surface refining agents and coating agents (Section C, IV); also strengthens the limit values of DEHP, DBP, and DIBP for the use of recycled fibers as raw materials for the production of paper.
• Recommendation XXXVI/1 on ‘Cooking Paper, Hot Filter Paper and Filter Layers’: expands the scope of silicates or mixed silicates to include sodium (Section I, B2 “Auxiliary agents”).
• Recommendation XXXXI/2 on Paper and Paperboard for Baking Purposes: expands the scope of silicates or mixed silicates to include sodium (Section I, B2 ‘Fillers’) and adds starch sodium octenyl succinate with specifications to expand the number of entries (Section III, D “Surface Refining Agents for the Food Contact Surface”)
• Recommendation LI on Temperature-Resistant Coating Systems Made of Polymers for Frying, Cooking and Baking Equipment: emphasizes that the conditions for food preparation utensils under classes FPU/H2, FPU/H3, and a modified time for FPU/H4 are applied (‘Testing conditions for kitchenware articles in contact with foodstuffs: Plastics, Metals, Silicone & Rubber, Paper & Board’ [Beldi et al., 2023]; specifies that testing with modified polyphenylene oxides (MPPO) is conducted at 175 °C for 2 hours (DIN EN 14338); indicates the use of the current version of the EQDM Technical Guideline for Metals and Alloys for element permeability testing; specifies ≤ 60 mg/kg for overall migration using 95% ethanol (60 °C for 6 hours) and isooctane (60 °C for 4 hours).

Who is impacted by this regulatory update?

Traders of articles intended to contact food substances and designed to German market will have to ensure that the formulations of raw materials used in production are compliant with the new specifications and that the product in its finished form complies with the indicated requirements.

UL Solutions can help you streamline market access across regional and international food contact materials regulations. We assist you in checking raw materials documentation and declarations and performing analytical tests on finisher articles.

Source

BfR Recommendations on Food Contact Materials