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SAFEGUARDS | Hardgoods & Food NO. 126/16

SafeGuardS bowl cup pot

In June 2016, the DGCCRF (the French General Directorate for Competition Policy, Consumer Affairs and Fraud Control) published new documents for food contact materials (FCMs) made from inorganic material (except metals), organic materials made from synthetic fibers and organic materials made from plant fibers.

In January 2016 we informed you about a new regulation of the French Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF, General Directorate for Competition Policy, Consumer Affairs and Fraud Control) on metals and alloys [1] in food contact materials. In June 2016 the DGCCRF published new documents for FCMs made from inorganic material (except metals), organic material made from synthetic fibers and organic materials made from plant fibers. The  respective recommendations documents DM/4B/COM/002, DM/4B/COM/003, DM/4B/COM/004 replace the specification in scope of Information Notice No. 2004-64 of 6 May, 2004.

The document DM/4B/COM/002 mandates the requirements for inorganic materials (except metals), especially ceramics, glass, glass-ceramic, and enamel

  • Introduction of new metal release limits for all articles except lip and rim area
  1. Aluminum (Al) < 1 mg/kg
  2. Cobalt (Co) < 0.02 mg/kg)
  3. Arsenic  (As) < not detectable (acceptable limit of quantitation 0.002 mg/kg)
  • Test conditions for the migration of new metals (Al ,Co, As) :
  1. Successive migration for 24 h at 22°C in 4% acetic acid
  2. Conformity assessment based on test result of the third contact for multiple use articles
  • Definition for cooking articles, included micro-wave articles (categories 3) with or without labelling (plate, bowl, mug,…)
  • Harmonization in categories between ceramics and glass/glass-ceramic/enamel
  • No change for the limit of lead and cadmium release.

The document DM/4B/COM/003 mandates the requirements for organic material made of synthetic fibers, especially plastics, complex material (multilayer) and rubber

  • No technical change from the old note (just updating references of regulation)
  • For rubber, the French decree 9/11/1994 is still valid. The European Regulation (EC) No 10/2011 is applicable to plastics and plastic layers in complex materials 

The document DM/4B/COM/004 mandates the requirements for organic material made of plant fibers, especially paper and board, with or without coating.

  • No technical change from the old note (just updating references of regulation)

In the scope of these documents, tablecloth has been removed from the exemption as FCM of the old note. Consequently such products are now considered as FCM irrespective from the materials they are made from.

A summary of all French recommendations [2] related to FCMs are given in Table 1.

References of French recommendations Scope
NI 2014-108 General requirements
DM-4B-COM-001-v01 Metal
DM-4B-COM-002-v01 Ceramic/glass/enamel/crystal
DM-4B-COM-003-v01 Plastic (p 5-9)
Complex materials (p 10-13)
Rubber (p 14-16)
DM-4B-COM-004-v01 Paper & board (p 4-8)
Paper and board with coating (p 9-10)
NI 2012-93 Wood

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.

For enquiries, please contact:

Pascale Lambert

Global Food contact Expert
t: +0033 23507 9266

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