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Belgium Regulates Food Contact Metals and Alloys

SafeGuardSFood Contact Material, Consumer Goods and Retail Hardgoods Food Contact MaterialMarch 29, 2021

Belgium has established requirements for food contact metals and alloys. These became effective on March 15, 2021.

On March 15, 2021, the Belgian Federal Public Service (FPS) Public Health, Food Chain Safety and Environment published Royal Decree of February 17, 2021 (2021/40623 in French and Dutch) to regulate food contact metals and alloys.

The new law contains, inter alia, several important provisions. It:

 

  • Clarifies that the scope applies to coated and uncoated food contact metal and alloy materials and articles in their final state 
  • Adopts the specific release limits (SRLs) from Council of Europe Resolution CM/Res (2013) 9 ‘Metals and Alloys Used in Food Contact Materials and Articles – A Practical Guide for Manufacturers and Regulators’ by the European Directorate for the Quality of Medicines & Healthcare (EDQM)
  • Clarifies that these materials and articles must be manufactured according to Regulation (EC) 1935/2004 (Framework Regulation, consolidated to August 2009), Regulation (EC) 2023/2006 (Good Manufacturing Practice, GMP, consolidated to April 2008) and Belgian Royal Decree of May 11, 1992 on food contact materials and articles (in French or Dutch)
  • Requires testing to be conducted using worst foreseeable conditions and in accordance with known national or European test methods on food contact metals and alloys
  • Requires the specific release values of a finished product to be expressed in mg/kg on the exact surface area to volume ratio under actual or expected conditions of use. For sheets, films, and flat surfaces that are not yet in contact with food, the migration values are to be expressed in mg/kg based on a surface to volume ratio of 6 dm² per kg of food
  • Requires a declaration of conformity (DoC, Chapter 2 to Annex of this Decree) – this is valid for five years if there are no changes in the manufacturing process

The Royal Decree does not specify an effective date. This can be considered as March 15, 2021 – the date of its publication in the nation’s official journal.

Highlights of the specific release limits (SRLs) for 1) metal and alloy components as well as 2) metals as contaminants and impurities in the new Royal Decree are summarized in Tables 1 and 2.

Royal Decree of February 17, 2021 on Metal and Alloy Materials and Articles Intended to Come into Contact with Food
ItemNameSymbolSRL (mg/kg food)ItemNameSymbolSRL (mg/kg food)
1Aluminum
Al
5.0
 9Molybdenum
Mo
0.12
2Antimony
Sb
0.04
 10Nickel
Ni
0.14
3Chromium
Cr
0.25
 11Silver
Ag
0.08
4Cobalt
Co
0.02
 12Tin
Sn1
100
5Copper
Cu
4.0
 13Titanium
Ti
---
6Iron
Fe
40
 14Vanadium
V
0.01
7Magnesium
Mg
---
 15Zinc
Zn5.0
8Manganese
Mn
1.8
 
1Except in the field of application under Regulation (EC) 1881/2006

Table 1. SRLs for metal and alloy components

 

Royal Decree of February 17, 2021 on Metal and Alloy Materials and Articles Intended to Come into Contact with Food
ItemNameSymbolSRL (mg/kg food)ItemNameSymbolSRL (mg/kg food)
1Arsenic
As0.0025LeadPb
0.01
2Barium
Ba
1.26Lithium
Li
0.048
3Beryllium
Be
0.017Mercury
Hg
0.003
4Cadmium
Cd
0.0058Thallium
Tl0.0001

Table 2. SRLs for metals as contaminants and impurities

 

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, paving the way for compliance. From overall migration tests to expert advice on emerging regulations, compliance issues and documentation review, SGS is the partner to trust. In the end, it’s only trusted because it’s tested.

For enquiries, please contact:

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

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