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Belgium Regulates Food Contact Varnishes and Coatings

Photo: Belgium regulates food contact varnishes and coatings
Photo: Belgium regulates food contact varnishes and coatings

The Belgian FPS has published a Royal Decree on food contact varnishes and coatings. The new law enters into force on January 1, 2017.

In October 2016, the Belgian Federal Public Service (FPS) Health, Food Chain Safety and Environment published Royal Decree of September 25, 2016 relating to food contact varnishes and coatings

According to the definitions in the Decree, varnishes and coatings (collectively known as varnish) are finished materials that are prepared essentially from organic materials and are applied to a substrate in the form of a film to create a protective layer and/or to impart certain technical properties.

The new law mirrors many of the provisions falling under Regulation (EU) 10/2011 on ‘Food Contact Plastics’, including the use of authorized substances that are listed in Annex I, selection of simulants, testing conditions and migration limits. It is interesting to note that citric acid is used for the specific migration of varnishes on metal.

There are two effective dates:

  • January 1, 2017 for entry into force of the Royal Decree.
  • January 1, 2018 for verification compliance of specific migration in Article 8 of this Decree, unless migration tests obtained prior to the date of entry into force of this Decree are satisfied.

Highlights of the new law on are summarized in the table below.

 1 Scope
  • Varnishes for metal materials and articles
  • Varnishes for flexible materials and articles
  • Varnishes for high capacity agri-food applications
additives and
starting substances

Substances in Annex I to Regulation (EU) 10/2011 on ‘Food Contact Plastics’ may be used

Substances not in Annex I to Regulation (EU) 10/2011 may be used provided that:

 3Food simulants
  • 3% Acetic acid
  • Citric acid (5g/L) for specific migration of varnishes and coatings on metal
  • Ethanol (10%, 20%, and 50%)
  • Vegetable oil
  • Poly(2,6-diphenyl-p-pheyleneoxide), particle size 60-80 mesh, pore size 200 nm
 4Global migration limit≤10 mg/dm² otherwise
≤60 mg/kg for infants and young children, as defined in Regulation (EU) 609/2013
 5Specific migration limit (SML)
  • According to Annex I to Regulation (EU) 10/2011 on ‘Food Contact Plastics’
  • ≤60 mg/kg for substances without a SML.
  • Specific migration of metals under Resolution CM/Res (2013) 9 of the Council of Europe do not apply to varnishes on metal.
 6Declaration of compliance (DOC)According to Article 9 (Chapter 3 of Appendix)

Royal Decree of 25 September, 2016 concerning varnishes and coatings intended to come into contact with food

SGS technical experts have extensive knowledge and testing experience in materials and articles incontact with food. They work to ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. From overall migration test to expert advices on emerging regulations and compliance issues and documentation review, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

Email SGS Hong Kong Ltd. at mktg@sgs.com for enquiry or visit www.sgsgroup.com/hk.

Content provided by SGS Hong Kong Limited
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