Germany’s BfR Revises Food Contact Materials Database

SG 088/26

The German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) has revised its database concerning food contact materials (FCMs) and articles.

In June 2026, the BfR amended four recommendations for FCMs and articles:

• Recommendation XXI ‘Commodities based on natural and synthetic rubber’ by amending “Structure of the recommendations’, which includes new Recommendation XXI/3 ‘Consumer goods made of thermoplastic elastomer vulcanizates (TPV)’
• Recommendation XXI/1 ‘Commodities based on natural and synthetic rubber in contact with food’ by revising the name in the title and deleting the paragraph concerning a) the use of rubber listed in Table 1 in combination with specified copolymers and b) nitrile rubber in combination with polyvinyl chloride (PVC)
• Recommendation XXI/2 ‘Special consumer goods based on natural and synthetic rubber and on latices made of natural and synthetic rubber (formerly special category)’ by revising the name in the title of the recommendation
• Recommendation XXXV ‘Copolymers of ethylene, propylene, butylene, vinyl esters and unsaturated aliphatic acids, and their salts and esters’ by replacing part B of the recommendation with ‘Recommendation XXI/3 can be used for the manufacture of TPVs’ 

Additionally, BfR introduced the new Recommendation XXI/3 ‘Consumer goods made of thermoplastic elastomer vulcanizates (TPV)’ as part of the series of recommendations for FCMs and articles.

These recommendations are available in German and English.

What does Recommendation XXI/3 require?

Key provisions in this recommendation include:

• Clarifying that the scope applies to food contact goods made of TPV within the meaning of the German Food and Feed Code (Lebensmittel- und Futtermittelgesetzbuch, LFGB)
• Specifying that the cross-linking agents identified in Table 1 of the recommendation are authorized only on a provisional basis, with such listing remaining valid until May 31, 2029
• Introducing the terms ‘Thermoplastic elastomers (TPEs)’ and ‘Thermoplastic vulcanizates (TPVs)’ and their definitions
• Specifying that tests must be conducted on the finished cross-linked TPV, with conditions and the classification of categories in accordance with Recommendation XXI/1
• Establishing the following guidelines for migration values:
  • Overall migration limits, specific migration limits and residual content limits for thermoplastic components are in accordance with Regulation (EU) No 10/2011 on food contact plastics (consolidated version to February 2026) 
  • Requirements in Recommendations XXI and XXI/1 apply to polymer components based on natural and synthetic rubber 
  • Requirements in Recommendation XXI/3 must also be respected
• Authorizing the use of substances and requirements for thermoplastics, rubber components and cross-linking agents in the manufacture of goods made of TPVs 
• Stipulating that finished goods must be ‘negative’ for peroxides

Who is impacted?

The recommendations affect stakeholders across the FCMs and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in the German market.

When does it apply?

The amended and newly introduced recommendations apply from June 1, 2026.

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We provide comprehensive FCM testing, including migration tests, along with expert guidance on evolving regulations, compliance issues and documentation review. Our expertise ensures your products meet the appropriate territorial regulations for food contact materials and helps pave the way for compliance. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.