Whilst much of the national legislation relating to food contact materials has been repealed and replaced with harmonised food contact regulation, there are still numerous material classes excluded from harmonised legislation – and therefore national legislation still applies to these materials.

These materials include: 
  • Paper and cardboard: covered in Germany by BfR recommendation XXXVI and in the Netherlands by the Warenwet
  • Colourants in plastics: subject to a positive list under French legislation
  • Rubber and elastomers: subject to BfR recommendations.
The EU have also not introduced any specific legislation relating to paper in contact with foodstuffs, but it is still covered by the general requirements of the Framework Regulation 1935/2004. In order to demonstrate compliance , the most common approaches are to ensure that the paper material meets one of the following:
  • Requirements of the national legislation in an EU member state (e.g. the German BfR recommendations or the Dutch Warenwet)
  • The standards set out in the draft Council of Europe resolution on food contact papers.
 We can help you:
  • Identify the relevant European national legislation for your material
  • Understand the legislative requirements and develop a testing programme to demonstrate compliance
  • Interpret your results to understand whether your material is fit-for-market.
The Smithers difference:
  •  Experts who keep up-to-date with regulatory changes, and who are regular speakers at world-leading conferences and training course leads
  • Our experts have been helping clients demonstrate food contact regulatory compliance since 1985. 

Download a brochure for more information:

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