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Market surveillance authorities in the European Union (EU) are increasingly turning their attention to food contact materials and products (FCM) that use composite materials containing bamboo powder or fibers as filler or additive materials. Figures from the EU’s Rapid Alert System for Food and Feed (RASFF) have shown a large increase in notifications during the first half of 2019 – so far there have been more notifications than in the whole of 2018.

The issues relate to FCM that contain bamboo powder or fiber contained within a melamine resin, which acts as the structural or shaping compound. Products include bowls, cups and tableware.

Many notifications under RASFF are based on excessive migration of formaldehyde and melamine from these products. This stems from the fact that bamboo products (bambooware) are deemed to be plastic products and are therefore governed by Regulation (EU) No. 10/2011. They must therefore comply with the following specific migration limits (SML):

  • Formaldehyde - 15 mg/kg
  • Melamine - 2.5 mg/kg

The German magazine, Stiftung Warentest, has published a report on twelve bamboo cups that found over half exceed migration levels, especially when containing hot acidic foods. To avoid similar problems, manufacturers are advised to follow good manufacturing practice.

Tests performed by SGS have shown that applicable SMLs can be kept and that best in class products do not pose food safety concerns. It is also important that consumers follow instructions, such as ‘do not use in microwaves’.

Concerns have also been raised over misleading labeling/advertising. This often includes words such as ‘sustainable’, ‘recycled’, ‘natural’, ‘organic’, and ‘compostable’. These words are misleading because they make consumers believe what is a plastic product only contains the natural materials. This has been addressed by the German Federal Institute of Risk Assessment (BfR) commodities commission.

Another issue that has been identified is the use of potentially non-authorized filler bamboo powder. Regulation (EU) No. 10/2011 requires that only substances included in the Union list of authorized substances, set out in Annex I, may be used intentionally for manufacturing. This raises concerns about the marketability of products containing bamboo powder, since it is not an explicitly listed substance alongside wood flour and fibers. The European Food Safety Authority (EFSA) is currently re-assessing entry No. 96, under mandate M-2019-0033, with an EFSA report expected by the end of 2019.

The European Commission has highlighted the necessity for Regulation (EU) No. 10/2011 to provide an appropriate framework to provide Member States and the industry with clarity in determining compliance, as these natural additives may not be clearly defined under FCM No. 96.

Currently, it is possible for authorities to interpret bamboo as non-wood, potentially making the plastic material non- compliant, as bamboo is not an authorized additive. As an example, the Ministry of Environment and Consumer Protection of the German Federal State of Saarland follows this stricter interpretation and has objected to 14 out of 15 tested samples due to their material composition – use of a non-authorized additive. It is hoped that EFSA’s update of the risk assessment for wood flour and fibers will help to settle this interpretation.

SGS Food Contact Material Services

SGS’s technical experts have extensive experience of testing materials and articles in contact with food. They can ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. SGS offers the full range of testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Learn more about SGS’s Food Contact Material Services.


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For more information, please contact:

Dr. Udo Krischke
Global Technical Manager RSTS
Tel: +49 6128 744 235

Email: crs.media@sgs.com

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