EU STRENGTHENS CHEMICAL SAFETY IN

FOOD CONTACT PLASTICS

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May 4, 2017

SAFEGUARDS | Consumer Products NO. 075/17

The EU has recently amended its Food Contact Plastics Regulation.

This amendment will be implemented in two phases starting May 19,
2017.
In January 2011, the European Union (EU) published Regulation (EU) 10/2011 to regulate
food contact plastics. This comprehensive piece of legislation established specific
requirements for plastic materials and articles which are intended or could reasonably be
expected to come into contact with food, or are already in contact with food.

In August 2016, we informed you that the Food Contact Plastics Regulation was
substantially amended [1] (http://www.sgs.com/en/news/2016/09/safeguards-14716-eu-
amends-food-contact-plastics) by Regulation (EU) 2016/1416. This included, among other
things, a new list of authorized substances, new restrictions, a newly defined set of
simulants for fresh or chilled fruit and fresh or chilled vegetables, and a new definition for
hot-fill.

On April 29, 2017, the EU published Regulation (EU) 2017/752 [2] (http://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R0752&from=EN) to amend
the Food Contact Plastics Regulation. This amendment contains a number of important
changes, including:

A completely new entry for the specific migration of nickel, restricting it to no more
than 0.02 mg/kg (Item 8, Table 1) in point 1 to Annex II (Restrictions on materials and
articles). The number of specific migration of heavy metals restrictions has increased
from 8 to 9

Adding 6 substances to the authorized list of substances

Editorial changes to Table 3 in point 4 to Annex III (Food simulant assignment for
demonstrating compliance with the overall migration limit) by establishing the
information in the form of a table for ease of reference

Replacing the residual content requirements of 10 substances with specific migration

limits

There are two effective dates:

May 19, 2017 for Regulation (EU) 2017/752 (except for the specific migration of nickel
falling under point 1 to Annex II)

May 19, 2019 for the specific migration of nickel falling under point 1 to Annex II

According to the amendment, food contact plastics complying with Regulation (EU) 10/2011
as applicable before the entry into force of Regulation (EU) 2017/752, may be placed on the
market until May 19, 2018 and may remain on the market until stocks are exhausted.
Highlights of a comparison of the specific migration of heavy metals falling under point 1 to
Annex II of Regulation (EU) 10/2011 are summarised in Table 1.

Point 1 of Annex II to Regulation (EU) 10/2011 relating to specific migration limits (in
food or food simulant) for heavy metals in food contact plastics
Regulation (EU) 2017/752 Regulation (EU) 2016/1416 Regulation
Item Metal amending Regulation (EU) amending Regulation (EU) (EU)
10/2011 10/2011 10/2011
Not
1 Aluminum 1 mg/kg 1 mg/kg
restricted
2 Barium 1 mg/kg 1 mg/kg 1 mg/kg
3 Cobalt 0.05 mg/kg 0.05 mg/kg 0.05 mg/kg
4 Copper 5 mg/kg 5 mg/kg 5 mg/kg
5 Iron 48 mg/kg 48 mg/kg 48 mg/kg
6 Lithium 0.6 mg/kg 0.6 mg/kg 0.6 mg/kg
7 Manganese 0.6 mg/kg 0.6 mg/kg 0.6 mg/kg
Not
8 Nickel 0.02 mg/kg Not restricted
restricted
9 Zinc 5 mg/kg 5 mg/kg 25 mg/kg
Effective date May 19, 2019 September 14, 2018 May 2011

SGS technical experts have extensive knowledge and testing experience in materials and
articles in contact with food. They work to ensure that your products meet the appropriate
regulations for food contact materials and pave the way for compliance. From overall
migration test to expert advices on emerging regulations and compliance issues and
documentation review, SGS is the partner to trust. Please do not hesitate to contact us for
further information or visit our website (http://www.sgs.com/en/Consumer-Goods-
Retail/Hardgoods/Home-Furnishings-and-Houseware.aspx).

For enquiries, please contact:

Hing Wo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

Stay on top of regulatory changes within your industry: subscribe to SafeGuardS

(http://www.sgs.com/en/Newsletters/Global/SafeGuards-and-Product-Recalls.aspx)!
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