In August 2024, the German Federal Institute for Risk Assessment (BfR) announced significant updates to its recommendations for materials and articles that come into contact with food. These changes, which apply to silicones, paper and board, specialized baking papers, and temperature-resistant coatings, are already in effect. While all five revised guidelines introduce noteworthy updates, the most substantial focus is on Recommendation XXXVI, which addresses the use of paper and board in food contact applications by including stricter limits on phthalates.
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Strengthened Controls for Paper and Board
Recommendation XXXVI, which governs paper and board intended for food contact use, underwent significant revisions aimed at enhancing chemical safety and environmental sustainability. Among the most critical changes are stricter migration limits for three key phthalates—diethylhexyl phthalate (DEHP), di-n-butyl phthalate (DBP), and diisobutyl phthalate (DIBP):
- DEHP: Lowered from 1.5 mg/kg to 0.6 mg/kg.
- DBP: Reduced from 0.3 mg/kg to 0.12 mg/kg.
- DIBP: Reduced from 0.3 mg/kg to 0.15 mg/kg.
Additionally, the cumulative migration limit for these substances is now capped at 0.6 mg/kg, with a new weighted formula introduced for calculating compliance. This formula (DBP × 5 + DIBP × 4 + DEHP × 1) ensures a stricter assessment of their combined presence.
Beyond the focus on phthalates, Recommendation XXXVI also reflects advances in material science by expanding the list of permissible additives. Sodium benzoate, for instance, has been added to the list of approved preservatives, while polyvinyl alcohol (PVA) joins the list of wet-strength agents.
Updates Across Other Material Categories
While the revisions to Recommendation XXXVI represent the most extensive changes, the BfR has also introduced important updates to its guidelines for other materials.
Silicones, addressed under Recommendation XV, now have greater flexibility in testing protocols. The updated guidelines remove the requirement for extractable components and introduce alternative testing conditions for volatile organic compounds.
For cooking and baking papers, covered by Recommendations XXXVI/1 and XXXVI/2, the updates expand the scope of approved substances. These include silicates and starch sodium octenyl succinate, which enhance the functionality and safety of materials designed for high-temperature use.
What These Changes Mean for the German Industry
The revised recommendations reflect Germany’s proactive approach to addressing both consumer health and environmental sustainability. The stricter controls on phthalates in recycled paper products align with growing concerns about chemical migration into food. Simultaneously, the expanded list of additives and refined testing protocols provide manufacturers with clearer pathways to compliance while encouraging innovation in food-safe materials.
You can find the amended recommendations here.
