SAFEGUARDS | Consumer ProductsNO. 128/20
On August 11, 2020, France published Order of August 5, 2020 to regulate food contact rubber materials and articles, as well as pacifiers for young children (‘new Order’). This new Order replaces and repeals the Order of November 9, 1994 (consolidated version to June 2020 for reference) relating to rubber materials and articles in contact with foodstuffs, food products and drinks.
The new law contains, inter alia, several important changes. It:
Clarifies the definition of rubber materials to include vulcanized thermoplastic elastomers, but not silicone elastomers
- Updates the lists of authorized substances for the manufacture of rubber materials and articles intended to come into contact with food and pacifiers for infants and young children
- Updates the restrictions and specifications for these authorized substances due to new scientific information, including specific migration limits (SMLs)
- Updates certain rules for verifying the conformity of rubber materials and articles
- Adds a completely new requirement for declaration of compliance (Doc)
- Expresses overall migration limits (OMLs) and their requirements in one of two specifications:
- ≤ 10 mg/dm² for 1) all articles 2) pacifiers for infants and young children and 3) gaskets, valves and valve elements where the ratio between the surface in contact with food and the volume is not known or specified
- ≤ 60 mg/kg for 1) food contact materials and articles for infants and young children 2) bottle nipples (teats) and 3) gaskets, valves and valve elements where the ratio between the surface in contact with food and the volume is known or specified
The new Order will become effective on July 1, 2021.
Food contact rubber materials and articles complying with the existing Order before the new Order enters into force, and which were placed on the market for the first time before July 1, 2021, may continue to be marketed until stocks are exhausted.
Highlights of some important provisions in the new Order are summarized in Table 1.
|Order of August 5, 2020 relating to Rubber Materials and Articles Intended to Come into Contact with Food and Pacifiers for Infants and Young Children|
Scope of Products:
Food contact rubber materials and articles in their finished state are obliged to comply with the following*:
≤ 0.5% ± 0.1% (volatile organic matter, VOM)
Specific migration of metals:
≤ 1.2 mg/kg (barium)
*See body text for overall migration (OM)
|Article 7||Details the compliance control for SMLs and OMLs, including the table of testing conditions in Annex III for measuring SMs and OMs|
Bottle nipples (teats) and pacifiers made of elastomeric and rubber materials for infants and young children are to tested according to the method in Part A to Annex IV for the following requirements:
|Article 12||Details the requirements for a DoC, including the information required in Annex V|
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