Food Contact Materials: Germany Updates Recommendations for Food Contact Materials

Silicone (Recommendation XV)

Delete the requirement for extractable components and provide 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.

Emphasize 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.

Paper and paperboard (Recommendation XXXVI)

Expand the number of sizing agents (Section BI), retention agents (see Section B, III), preservatives including sodium benzoate (Section B, VIII), wet-strength agents including polyvinyl alcohol (PVA, Section C, I), surface refining agents and coating agents (Section C, IV).

Strengthen the limit values of DEHP, DBP and DIBP for the use of recycled fibers as raw materials for the production of paper.

Cooking paper, hot filter paper and filter layers (Recommendation XXXVI/1)

Expand the scope of silicates or mixed silicates to include sodium (Section I, B2 ‘Auxiliary agents’).

Paper and paperboard for baking purposes (Recommendation XXXXI/2 on)

Expand the scope of silicates or mixed silicates to include sodium (Section I, B2 ‘Fillers’) and add starch sodium octenyl succinate, with specifications to expand the number of entries (Section III, D: ‘Surface refining agents for the food contact surface’).

Temperature-resistant coating systems made of polymers for frying, cooking and baking equipment (Recommendation LI)

Emphasize 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)).

Specify that testing with modified polyphenylene oxides (MPPO) is conducted at 175 °C for two hours (DIN EN 14338).

Indicate the use of the current version of the EQDM Technical Guideline for Metals and Alloys for element permeability testing.

Specify ≤ 60 mg/kg for overall migration using 95 percent ethanol (60 °C for six hours) and isooctane (60 °C for four hours).