New Food Contact Metal and Alloy Regulation in Belgium

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):
    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
Contact Material
s 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

Subscribe here to receive SGS SafeGuardS direct to your inbox.

For further information contact:

HingWo Tsang

Global Information and Innovation Manager

Tel: (+852) 2774 7420



LinkedIn: sgs-consumer-goods-&-retail

About SGS

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 89,000 employees, SGS operates a network of over 2,600 offices and laboratories around the world.

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