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

The German Federal Institute for Risk Assessment (BfR) is a scientific institution that undertakes the task of assessing risks, identifying new health risks, and formulating 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 food contact recommendations for silicone, paper (including food contact paper, cooking paper, thermal filter paper, baking paper, etc.), and high temperature resistant coatings. The updated recommendations will take effect from the date of publication.

The updated recommendation numbers are as follows:

No.

Name

XV

Silicone

XXXVI

Paper for food contact

XXXVI/1

Cooking paper, thermal filter paper and filter paper

XXXVI/2

Paper and board for baking

LI

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

The main updates to the index requirements and test methods are as follows:

Serial number

No. Name

Update content

1

BfR Recommendation XV-Silicone

1. Modify the test conditions for volatile organic compounds: Products that are not resistant to high temperatures should select test conditions according to Table 3 of Annex V of (EU) No 10/2011. The test conditions of this test item in the old version are fixed at 200℃, 4h.

2. Delete the requirement that the extractable content of silica gel in water, 3% acetic acid and 10% ethanol must be less than 0.5%.

2

BfR Recommendation XXXVI-Paper for food contact

1. The requirements for raw materials such as adhesives, preservatives, and wet strength agents have been updated for paper products.

2. The migration limits of plasticizers have changed:

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

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

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

DBP+DEHP+DIBP total migration limit: 0.6mg/kg (using the formula Ʃ = DBPx5 + DIBPx4 + DEHPx1, calculated in DEHP), which is slightly different from the calculation in the EU plastics regulations.

3

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

1. Added a total migration limit of 10 mg/dm2, and the test conditions are 95% ethanol (60°C, 6h) and isooctane simulant (60°C, 4h).

2. Added metal substrate requirements, tested according to the latest EDQM requirements. For related content, please refer to the previous article "EU Releases Second Edition of Guidelines for Metals and Alloys in Food Contact Materials";

3. Modified the test conditions for specific migration, deleted the old test conditions, and modified the test conditions to the test conditions FPU/H2, FPU/H3 and FPU/H4 corresponding to plastics in the JRC Guide "Test Conditions for Kitchen Utensils in Food Contact: Plastics, Metals, Silicone Rubber and Rubber, Paper and Cardboard". One exception is that the test time of FPU/H4 is reduced from 8h to 4h. Because 8 hours of migration with 3% acetic acid may cause corrosion of objects, which is an uncommon phenomenon in practical applications. The dry simulant MPPO test is revised to DIN EN 14338, with a test condition of 175℃ for 2h;

Note: The specific migration test is performed three times on the same sample, using different food simulants each time. The compliance judgment is based on the third test result. For substances that must not be detected at a specific migration limit, the migration limit must be met in the first test. This paragraph requires clarification of the compliance judgment, and coated products do not need to undergo three trend judgments in accordance with the EU Plastics Revision Directive EU 2020/1245.

LCS Recommendation:

Although the BfR Recommendation is not legally binding, it is widely recognized by the industry and has become an important reference for products to enter the German market. It is recommended that relevant companies pay attention to the updated content this time and do a good job of compliance work for related products as soon as possible.