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Food Contact

In January 2011, the European Union (EU) published Regulation (EU) 10/2011 to regulate food contact plastics. This comprehensive piece of legislation established specific requirements for plastic materials and articles which are intended or could reasonably be expected to come into contact with food, or are already in contact with food.

In August 2016, we informed you that the ‘Food Contact Plastics’ Regulation was substantially amended [1] by Regulation (EU) 2016/1416. This included, among other things, a new list of authorized substances, new restrictions, a newly defined set of simulants for ‘fresh or chilled fruit’ and ‘fresh or chilled vegetables’, and a new definition for ‘hot-fill’. 

On April 29, 2017, the EU published Regulation (EU) 2017/752 [2] to amend the ‘Food Contact Plastics’ Regulation. This amendment contains a number of important changes, including:

  • A completely new entry for the specific migration of nickel, restricting it to no more than 0.02 mg/kg (Item 8, Table 1) in point 1 to Annex II (Restrictions on materials and articles). The number of specific migration of heavy metals restrictions has increased from 8 to 9
  • Adding 6 substances to the authorized list of substances Editorial changes to Table 3 in point 4 to Annex III (Food simulant assignment for demonstrating compliance with the overall migration limit) by establishing the information in the form of a table for ease of reference
  • Replacing the residual content requirements of 10 substances with specific migration limits

There are two effective dates:

  • May 19, 2017 for Regulation (EU) 2017/752 (except for the specific migration of nickel falling under point 1 to Annex II)
  • May 19, 2019 for the specific migration of nickel falling under point 1 to Annex II 

According to the amendment, food contact plastics complying with Regulation (EU) 10/2011 as applicable before the entry into force of Regulation (EU) 2017/752, may be placed on the market until May 19, 2018 and may remain on the market until stocks are exhausted.

Highlights of a comparison of the specific migration of heavy metals falling under point 1 to Annex II of Regulation (EU) 10/2011 are summarised in Table 1.


Point 1 of Annex II to Regulation (EU) 10/2011 relating to specific migration limits (in food or food simulant) for heavy metals in food contact plastics
Item Metal Regulation (EU) 2017/752 amending Regulation (EU) 10/2011 Regulation (EU) 2016/1416 amending Regulation (EU) 10/2011 Regulation (EU) 10/2011
1 Aluminum 1 mg/kg 1 mg/kg Not restricted
2 Barium 1 mg/kg 1 mg/kg 1 mg/kg
3 Cobalt 0.05 mg/kg 0.05 mg/kg 0.05 mg/kg
4 Copper 5 mg/kg 5 mg/kg 5 mg/kg
5 Iron 48 mg/kg 48 mg/kg 48 mg/kg
6 Lithium 0.6 mg/kg 0.6 mg/kg 0.6 mg/kg
7 Manganese 0.6 mg/kg 0.6 mg/kg 0.6 mg/kg
8 Nickel 0.02 mg/kg Not restricted Not restricted
9 Zinc 5 mg/kg 5 mg/kg 25 mg/kg
Effective date May 19, 2019 September 14, 2018 May 2011

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 more information:

Sara de Miguel

About SGS

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