The public consultation on the draft revision of the German Federal Institute for Risk Assessment (BfR) Recommendations on paper and board for food contact closed on 30 June 2026. The consultation, announced in April 2026, concerned a structural overhaul of the four existing recommendations covering paper and board materials in food contact: XXXVI, XXXVI/1, XXXVI/2 and XXXVI/3. The window for industry input has now closed and the revised recommendation is expected to move toward formal publication in the coming months.
TABLE OF CONTENTS
Why the BfR Recommendations Matter Beyond Germany
BfR Recommendations are technically national German guidelines, but because there is no specific EU-wide regulation for paper, they are used across Europe as the de facto safety standard for paper and board food contact materials. The four recommendations cover distinct application areas:
- BfR XXXVI – paper and board for food contact at temperatures up to 90°C
- BfR XXXVI/1 – cooking papers, hot filter papers and filter layers
- BfR XXXVI/2 – paper and paperboard for baking purposes, up to 220°C
- BfR XXXVI/3 – absorber pads based on cellulosic fibers for food packaging
Together they represent the compliance baseline for a significant proportion of paper-based food packaging in use across European markets.
What the Revision Actually Changes
The draft revision focuses on structural improvements, traceability and clarity, not new regulatory requirements. According to BfR, the update does not include:
- New substance authorisations
- New migration limits
- New technical requirements for food contact materials
The four existing recommendations have been consolidated into a single unified document and reformatted from continuous text into tabular form, making substance listings easier to navigate. CAS Registry Numbers have been added to substance entries where known, improving traceability and reducing the ambiguity that can arise when substances are identified by chemical name alone.
One point requires careful attention: for entries where CAS numbers are provided, only those specific CAS numbers will be considered compliant upon the update’s publication. This means that a company using a substance previously covered under a broad category entry may need to verify whether their specific grade or form corresponds to a listed CAS number in the revised document.
The Broader Revision Program
The paper and board recommendations are not the only BfR guidelines currently under review. A parallel revision process is underway for Recommendations XXI, XXI/1 and XXI/2 on commodities based on natural and synthetic rubber.
The approach is consistent across both exercises: structural consolidation first, substantive technical revision to follow in later steps. For paper and board specifically, the BfR has indicated that further revisions are planned in the coming years. Potential updates to authorized substances, new restrictions or revised limits are expected to be addressed once the structural foundation is in place.
What This Means for Compliance
For companies producing or sourcing paper and board food contact materials, the immediate priority upon publication of the revised document is to cross-reference existing substance portfolios against the new consolidated version. The key questions to address are:
- Are the substances currently in use listed in the new tabular format with the correct CAS number?
- Does any substance previously covered under a broad category entry now correspond to a specific CAS number that may or may not match the grade in use?
- Does the consolidation of XXXVI/1, XXXVI/2 and XXXVI/3 into a single document require updating of compliance references in technical documentation and Declarations of Compliance?
The last point is particularly relevant for packaging converters and food producers who currently reference specific recommendation numbers in their supply chain documentation.
Conclusion
The closure of the BfR consultation marks the end of the input phase for the first stage of the paper and board recommendations revision. The outcome will be a more structured and traceable compliance document, though not a more demanding one at this stage. For the many European companies that rely on BfR Recommendation XXXVI as their primary reference for paper food contact compliance, the revised document warrants careful review upon publication, not because the rules are changing, but because the way substances are identified and referenced will be.
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