SAFEGUARDS | Food NO. 003/17

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The Netherlands has amended its technical requirements for certain food contact materials and articles falling under the Commodities Act Regulation. The new law became effective on January 1, 2017.

Part A [1] of the Dutch Commodities Act Regulation on Packaging and Consumer Articles Coming into Contact with Foodstuffs (Commodities Act (Packaging and Consumer Articles) Regulation [Warenwetregeling verpakkingen en gebruiksartikelen]) contains rules and requirements for 12 types of food contact material and articles. These are plastics (Chapter I), paper & cardboards (Chapter II), rubber (Chapter III), metals (Chapter IV), glass & glass ceramics (Chapter V), ceramics & enamels (Chapter VI), textiles (Chapter VII), regenerated cellulose films (Chapter VIII), wood & corks (Chapter IX), coatings (Chapter X), colorants & pigments (Chapter XI) and epoxy polymers (Chapter XII)

On November 3, 2016, the Dutch Minister for Public Health, Welfare and Sport published 1028394-156011-VGP of October 26, 2016 to amend the Commodities Act Regulation on packaging and consumer products. The new law, published under number 58058 in Staatscourant 2016 [2], contains a number of important changes, including:

  • Amending the list of authorized substances for plastics, paper & cardboards, metals and coatings.
  • Amending the specific migration limit (SML) for some organic chemicals used in plastic food contact materials (FCMs).
  • Amending the SML for total zirconium compounds (expressed as zirconium) in plastics to become less stringent (Table 1).
  • Amending the SML for zirconium in glass & glass ceramics to become less stringent; from 0.05 mg/kg to 2.0 mg/kg.
  • Requiring the use of 1.5% citric acid or the foodstuff itself for the specific migration of zirconium in passivated metals. The SML for zirconium in these food contact materials and articles has become less stringent; from 0.05 mg/kg to 2.0 mg/kg.

The amendment became effective on January 1, 2017.

Highlights of the SML for total zirconium compounds, expressed as zirconium, in plastics are summarized in Table 1.

Chapter I to Annex Part A of the Commodities Act Regulation on Packaging and Consumer Articles Relating to Plastics
Legislation Existing


(1028394-156011-VGP of October 26, 2016)

Zirconium compound (CAS)

Zirconium (IV) n-propoxide (23519-77-9)

Zirconium naphthalene (72854-21-8)

Zirconium octanoate (-)

Zirconium oxide (12036-01-0, 1314-23-4 and 53801-45-9)

SML requirement for total zirconium compounds ≤ 0.05 mg/kg  ≤ 2.0 mg/kg
Effective date In force January 1, 2017

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:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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