Belgium has published Royal Decree of
February 17, 2021 to regulate food contact metals and alloys. It does not
specify an effective date and therefore the publishing date should be used by
stakeholders as the date it came into effect – March 15, 2021.
Published by the Belgian Federal Public
Service (FPS) Public Health, Food Chain Safety and Environment , the decree regulates
food contact metals and alloys and includes several important provisions.
Stakeholders should be aware that the new law:
- Applies to coated and uncoated food
contact metal and alloy materials and articles in their final state - Clarifies that these materials and
articles must be manufactured according to Regulation (EC) 1935/2004,
Regulation (EC) 2023/2006 and Belgian Royal Decree of May 11, 1992 on food
contact materials and articles - Requires testing to be conducted using
worst foreseeable conditions and in accordance with known national or European
test methods on food contact metals and alloys - Requires the specific release values of a finished
product to be expressed in mg/kg on the exact surface area to volume ratio
under actual or expected conditions of use. For sheets, films, and flat
surfaces that are not yet in contact with food, the migration values are to be
expressed in mg/kg based on a surface to volume ratio of 6 dm² per kg of food - Requires a declaration of conformity (DoC,
Chapter 2 to Annex of this Decree) – valid for five years without changes to
the manufacturing process - Adopts the specific release limits (SRLs) from
Council of Europe Resolution CM/Res (2013) 9 ‘Metals and Alloys Used in food
Contact Materials and Articles – A practical guide for Manufacturers and
Regulators’ by the European Directorate for the Quality of Medicines &
Healthcare (EDQM)
The SRLs are:
Metal and alloy components:
- Aluminum (Al): 5.0 mg/kg food
- Antimony (Sb): 0.04 mg/kg food
- Chromium (Cr): 0.25 mg/kg food
- Cobalt (Co):
0.02 mg/kg food - Copper (Cu): 4.0 mg/kg food
- Iron (Fe): 40 mg/kg food
- Magnesium (Mg)
- Manganese (Mn): 1.8 mg/kg food
- Molybdenum (Mo): 0.12 mg/kg food
- Nickel (Ni): 0.14 mg/kg food
- Silver (Ag): 0.08 mg/kg food
- Tin (Sn): 100 mg/kg food
- Titanium (Ti)
- Vanadium (V): 0.01 mg/kg food
- Zinc (Zn): 5.0 mg/kg food
Metals as contaminants and impurities:
- Arsenic (As): 0.002 mg/kg food
- Barium (Ba): 1.2 mg/kg food
- Beryllium (Be): 0.01 mg/kg food
- Cadmium (Cd): 0.005 mg/kg food
- Lead (Pb): 0.01 mg/kg food
- Lithium (Li): 0.048 mg/kg food
- Mercury (Hg): 0.003 mg/kg food
- Thallium (Tl): 0.0001 mg/kg food
Stakeholders operating in Belgium are
advised to check their products conform to the new law governing food contact
metals and alloys.
SGS Food Contact Materials Services
SGS’s technical experts have extensive experience of testing materials and
articles in contact with food. They can ensure that your products meet the
appropriate regulations for food contact materials and pave the way for
compliance. SGS offers the full range of testing, including migration tests,
along with expert advice on emerging regulations, compliance issues and
documentation review. Learn more
about SGS’s Food
Contact Materials Services.
SGS SafeGuardS keep you up to date with the
latest news and developments in the consumer goods industry. Read the full Belgium
Regulates Food Contact Metals and Alloys SafeGuardS.
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For further information contact:
HingWo Tsang
Global Information and Innovation Manager
Tel: (+852) 2774 7420
Email: crs.media@sgs.com
Website: www.sgs.com/hardlines
LinkedIn: sgs-consumer-goods-&-retail
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