In February 2020, the German Federal Institute for Risk Assessment (BfR) is reported to have published updated versions of many of their recommendations on food contact materials (FCMs). The agency notes that these recommendations “are not legal norms,” and they are described as representing “the current state of the scientific and technical knowledge for the conditions under which consumer goods made of high polymer substances meet the requirements of § 31, para 1, German Food and Feed Code (Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch, LFGB) as well as those of Article 3, para 1 a of the Regulation (EC) No 1935/2004 in respect to their health safety.” The BfR has been publishing such recommendations since 1958.
The most recent updates are described as including changes to:
- Recommendation XXXVI on Paper and Board for Food Contact: including new migration limits for slimicides and aluminum as well as the addition of permitted slimicides, preservatives, and refining and coating agents.
- Recommendations XXXVI/1 on Cooking Paper, Hot Filter Papers, and Filter Layers and XXXVI/2 on Paper and Paperboard for Baking Purposes: including new restrictions on migration of aluminum into food and expanding permitted substances categorized as antimicrobial agents and preservatives, among others.
- Recommendation VII including updates to catalyst residues for polypropylene and Recommendation III to catalyst residues in polyethylene.
- Recommendation XIV on polymer dispersions: expanding the list of monomers that can be used
A full list of the most recent changes is provided in a summary document in German.
BfR (April 16, 2020). “Database BfR Recommendations on Food Contact Materials.”
Keller and Heckman LLP (April 16, 2020). “Germany Updates Food-Contact Recommendations.” Chemical Watch