The German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) has released a comprehensive set of updates affecting nine different types of food contact materials (FCMs) and articles. These updates, effective October 1, 2025, include eight revised recommendations and one withdrawal, refining safety and compliance expectations across materials such as polymers, silicones and paper-based products.
Table of Contents
Annex XXXVI: Paper and Board for Food Contact
The updated Annex XXXVI introduces significant tightening of requirements for paper and paperboard materials intended for direct or indirect food contact. Among the most notable changes:
- Migration limits strengthened: The allowable bisphenol A (BPA) migration level for recycled paper has been reduced from 0.05 mg/kg to 0.01 mg/kg, aligning with recent EU measures on bisphenols.
- New testing benchmarks: The previous footnote 8 has been replaced to require a gray scale 5 under EN 646 testing and an assessment level 5 under EN 648, referencing BfR’s own methods for paper, cardboard and paperboard.
- Acrylamide release control: A new preamble requirement mandates “Not Detected” (ND) acrylamide release, defined by a detection limit (DL) of 0.01 mg/kg, for finished products.
- Expanded material specifications: Additional entries now define clearer standards for fibrous materials, production aids and special paper refining agents.
- Mineral oil aromatic hydrocarbons (MOAH): A new footnote 36 addresses MOAH, reflecting growing concern over potential mineral oil contamination.
- Revised treatment of primary aromatic amines (PAA): The note has been repositioned as footnote 10 with updated text clarifying testing and compliance thresholds.
Collectively, these updates reinforce BfR’s intent to ensure paper and board FCMs meet higher safety, migration and testing standards, especially for recycled materials increasingly used in sustainable packaging.
Key Updates Across Other Annexes
Although Annex XXXVI received the most extensive changes, several other recommendations also saw revisions or clarifications:
- Annex XIV – Polymer Dispersions: Expands the list of emulsifying agents and introduces a new Category 3 for additives, covering microfibrillated cellulose.
- Annex XV – Silicone: Updates footnote 7 to reference Recommendation XXV for waxes and paraffins compliance.
- Annex XVII – Polyterephthalic Acid Diol Esters: Adds a new footnote limiting bisphenol A diglycidyl ether and references Regulation (EU) 2024/3190 concerning bisphenols.
- Annex XXX – Conveyor Belts Made from Gutta-Percha and Balata: Withdrawn entirely, with no replacement.
- Annexes XXXVI/1, XXXVI/2 and XXXVI/3 (covering cooking paper, baking paper and absorber pads): All now include the same ND (DL = 0.01 mg/kg) acrylamide release requirement introduced in XXXVI.
- Annex XLIV – Artificial Sausage Casings: Updates footnote 10 to align with Recommendation XXV for waxes and paraffins.
Implications for the Packaging Industry
These revisions will require manufacturers, converters and importers of food contact materials to review existing formulations and testing procedures to ensure ongoing compliance. In particular, the stricter migration limits and enhanced testing requirements for paper and board will demand close collaboration between material suppliers and packaging producers.
For companies emphasizing sustainable or recycled paper packaging, the new limits underscore the importance of robust contaminant monitoring and documentation to demonstrate conformity with BfR’s tightened standards.
Conclusion
With these updates, the BfR continues to strengthen its framework for safe food contact materials, addressing both chemical migration risks and evolving EU regulatory expectations. The sweeping revisions in Annex XXXVI confirm that paper and board materials remain a priority for risk assessment as the packaging industry moves toward circular and fiber-based solutions. All nine updated recommendations came into force on October 1, 2025, and are available in German and English through the BfR website.
