An update to French metal and alloy food contact materials

In November 2015, the French Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCFF, General Directorate for Competition Policy, Consumer Affairs and Fraud Control) published Document DM/4B/COM/001 to pose new requirements on food safety concerning metal and alloy food contact materials (FCMs). The document supersedes requirements on metal and alloy FCMs in DGCCRF NI No. 2004-64 on 1 January 2016.
 
In the document, food contact metals and alloys are categorised into 14 types posing different requirements on metals, including definitions, metal proportion, hazardous elements, migration limits, conditions of migration test (selection of stimulants, temperatures and period).
 
Compared with DGCCRF NI No. 2004-64, the main change lies in that an additional migration of 21 (23) heavy metals as per CoE Resolution CM/Res(2013) 9. The Annex I to the document lists requirements for the specific release of heavy metals.
 

(1) Specific release limit of metal and alloy components			(2) Specific release limit of metals as contaminants
Element	Name	LLS [mg/kg]	Element	Name	LLS [mg/kg]
Ag	Silver	0.08	As	Arsenic	0.002
Al	Aluminum	5	Ba	Barium	1.2
Co	Colt	0.02	Be	Beryllium	0.01
Cr	Chromium	0.250	Cd	cadmium	0.005
Cu	Copper	4	Hg	Mercury	0.003
Fe	Iron	40	Li	Lithium	0.048
Mg	Magnesium	-	Pb	Lead	0.010
Mn	manganese	1.8	Sb	Antimony	0.04
Mo	Molybdenum	0.12	Tl	Thallium	0.0001
Ni	Nickel	0.14
Sn	Tin	100
Ti	Titanium	-
V	Vanadium	0.01
Zn	Zinc	5

 
Remarks: The Document DM/4B/COM/001 covers the following:
1. Non-coated stainless steels
2. Aluminium and aluminium alloys with organic coating
3. Aluminium and aluminium alloys without coating
4. Steels without coating for packaging (‘Black Iron’)
5. Tin-plated steels for packaging
6. Steels with organic coating for packaging
7. Steels without coating not for packaging
8. Steels and stainless steels with metallic coating not for packaging
9. Steels and stainless steels with organic coating not for packaging
10. Cast iron without coating or with metallic coating
11. Cast iron with organic coating
12. Tin and tin alloys
13. Zinc and zinc alloys
14. Other metal articles with metallic coating
 
However, enamelled materials, materials with an inorganic coating and materials with an organic-mineral hybrid coating such as sol-gels are not covered therein.

Judging from EU recalls on food contact materials, we can see the strict regulation on such products. However, French regulation on metal and alloy food contact materials are more widely and detailed compared with other member states. C&K Testing advises companies to test heavy metals in FCMs to confirm conformity. Equipped with knowledgeable experts and advanced instruments, C&K Testing can assure you of product safety.

【中文版】

Further information
DGCCRF NI No. 2004-64 (in French)