Belgium has published Royal Decree of February 17, 2021 to regulate food contact metals and alloys. It does not specify an effective date and therefore the publishing date should be used by stakeholders as the date it came into effect – March 15, 2021.
Published by the Belgian Federal Public Service (FPS) Public Health, Food Chain Safety and Environment , the decree regulates food contact metals and alloys and includes several important provisions.
Stakeholders should be aware that the new law:
- Applies to coated and uncoated food contact metal and alloy materials and articles in their final state
- Clarifies that these materials and articles must be manufactured according to Regulation (EC) 1935/2004, Regulation (EC) 2023/2006 and Belgian Royal Decree of May 11, 1992 on food contact materials and articles
- 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) – valid for five years without changes to the manufacturing process
- 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)
The SRLs are:
Metal and alloy components:
- Aluminum (Al): 5.0 mg/kg food
- Antimony (Sb): 0.04 mg/kg food
- Chromium (Cr): 0.25 mg/kg food
- Cobalt (Co): 0.02 mg/kg food
- Copper (Cu): 4.0 mg/kg food
- Iron (Fe): 40 mg/kg food
- Magnesium (Mg)
- Manganese (Mn): 1.8 mg/kg food
- Molybdenum (Mo): 0.12 mg/kg food
- Nickel (Ni): 0.14 mg/kg food
- Silver (Ag): 0.08 mg/kg food
- Tin (Sn): 100 mg/kg food
- Titanium (Ti)
- Vanadium (V): 0.01 mg/kg food
- Zinc (Zn): 5.0 mg/kg food
Metals as contaminants and impurities:
- Arsenic (As): 0.002 mg/kg food
- Barium (Ba): 1.2 mg/kg food
- Beryllium (Be): 0.01 mg/kg food
- Cadmium (Cd): 0.005 mg/kg food
- Lead (Pb): 0.01 mg/kg food
- Lithium (Li): 0.048 mg/kg food
- Mercury (Hg): 0.003 mg/kg food
- Thallium (Tl): 0.0001 mg/kg food
Stakeholders operating in Belgium are advised to check their products conform to the new law governing food contact metals and alloys.
SGS Food Contact Materials 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 Materials Services.
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