SG 154/26
Luxembourg establishes new requirements for food contact metals and alloys.
On October 8, 2026, Luxembourg published the Grand-Ducal Regulation of July 24, 2026 (the Regulation), establishing requirements for metal and alloy materials and articles intended to come into contact with food.
What does the Regulation require?
Key provisions include:
- Authorizing operators to label uncoated aluminum materials and articles to indicate that they do not have a protective coating
- Requiring operators to provide advice on using aluminum materials and articles with acidic, alkaline or salty foods
- Directing operators to draw up a declaration of conformity (DoC) containing the information specified in Chapter 2 of Annex 2 to the Regulation
- Establishing SRLs for metals and alloy components (Table 1) and metals present as contaminants and impurities (Table 2)
- Setting a generic limit of 60 mg/kg, unless otherwise specified, for substances without a specific release limit (SRL), specific migration limit (SML) or other restriction
| Item | Element | SRL (mg/kg food) |
| 1 | Aluminum (Al) | 5 |
| 2 | Antimony (Sb) | 0.04 |
| 3 | Chromium (Cr) (VI) | 1 |
| 4 | Cobalt (Co) | 0.02 |
| 5 | Copper (Cu) | 4 |
| 6 | Iron (Fe) | 40 |
| 7 | Magnesium (Mg) | -----¹ |
| 8 | Manganese (Mn) | 0.55² |
| 9 | Molybdenum (Mo) | 0.12 |
| 10 | Nickel (Ni) | 0.14 |
| 11 | Silver (Ag) | 0.08 |
| 12 | Tin (Sn) | 100³ |
| 13 | Titanium (Ti) | -----¹ |
| 14 | Vanadium (V) | 0.01 |
| 15 | Zinc (Zn) | 5 |
| 16 | Zirconium (Zr) | 2 |
| ¹Generic limit of 60 mg/kg does not apply ²An SRL of 0.07 mg/kg applies to food intended for infants and young children under Regulation (EU) No. 609/2013 ³ Except where Regulation (EU) 2023/915 on maximum levels for certain contaminants in food applies | ||
Table 1. SRLs for metal and alloy components
| Item | Element | SRL (mg/kg food) |
| 1 | Arsenic (As) | 0.002 |
| 2 | Barium (Ba) | 1.2 |
| 3 | Beryllium (Be) | 0.01 |
| 4 | Cadmium (Cd) | 0.005 |
| 5 | Lithium (Li) | 0.048 |
| 6 | Mercury (Hg) | 0.003 |
| 7 | Lead (Pb) | 0.010 |
| 8 | Thallium (Tl) | 0.001 |
Table 2. SRLs for metals as contaminants and impurities
Who is impacted?
The Regulation affects stakeholders across the food contact metals and alloys supply chain, including manufacturers, importers, retailers and other intermediaries operating in Luxembourg.
When does it apply?
The Regulation entered into force on October 12, 2026.
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