Status and scope
Resolution CM/Res(2013)9 of the Committee of Ministers of the Council of Europe, with its accompanying EDQM Technical Guide “Metals and alloys used in food contact materials and articles,” sets specific release limits (SRLs) for metal ions released from metal and alloy food-contact materials into food. It is a Council of Europe resolution and technical guide rather than directly-applicable EU law. It functions as a harmonised European reference that member states may adopt into national law, as several have, and that industry and laboratories use as the benchmark where no binding national metal-release limit exists. On this wiki it is recorded as a comparator instrument, not as a sovereign maximum level: where a binding national migration standard exists, such as China’s GB 4806.9-2023, that national instrument is the maximum level and CM/Res(2013)9 is disclosed context.
Exact limits and units
SRLs are expressed in mg/kg food. Compliance requires that the release of each metal ion stay below the applicable SRL.
Table 1 - metals and alloy components
| Element | SRL (mg/kg) | SRL (µg/kg) |
|---|---|---|
| Aluminium (Al) | 5 | 5000 |
| Antimony (Sb) | 0.04 | 40 |
| Chromium (Cr) | 0.250 | 250 |
| Cobalt (Co) | 0.02 | 20 |
| Copper (Cu) | 4 | 4000 |
| Iron (Fe) | 40 | 40000 |
| Magnesium (Mg) | no limit set | no limit set |
| Manganese (Mn) | 1.8 | 1800 |
| Molybdenum (Mo) | 0.12 | 120 |
| Nickel (Ni) | 0.14 | 140 |
| Silver (Ag) | 0.08 | 80 |
| Tin (Sn) | 100 | 100000 |
| Titanium (Ti) | no limit set | no limit set |
| Vanadium (V) | 0.01 | 10 |
| Zinc (Zn) | 5 | 5000 |
Tin is limited to 100 mg/kg except in fields of application governed by Regulation (EC) No 1881/2006.
Table 2 - metals as contaminants and impurities
| Element | SRL (mg/kg) | SRL (µg/kg) |
|---|---|---|
| Arsenic (As) | 0.002 | 2 |
| Barium (Ba) | 1.2 | 1200 |
| Beryllium (Be) | 0.01 | 10 |
| Cadmium (Cd) | 0.005 | 5 |
| Lead (Pb) | 0.010 | 10 |
| Lithium (Li) | 0.048 | 48 |
| Mercury (Hg) | 0.003 | 3 |
| Thallium (Tl) | 0.0001 | 0.1 |
For antimony, cobalt, chromium, molybdenum, nickel, vanadium and the contaminants arsenic, beryllium, mercury and thallium, deviation from the SRL may be tolerated for analytical-limitation reasons subject to competent-authority approval. For cadmium and lead, deviation may be tolerated for certain applications subject to approval, with the ALARA principle applied.
Derivation basis
Each SRL was set from toxicological reference values (JECFA, EFSA or national risk-assessment bodies), oral-intake exposure assessments across several European countries, an allocation of a percentage of the toxicological reference value to food-contact release, and actual release data where a technically-feasible ALARA level was more appropriate than a value derived purely from toxicology.
How it compares
The SRLs are closely aligned with China’s statutory GB 4806.9-2023 migration limits: chromium 0.250, nickel 0.14, tin 100 and arsenic 0.002 mg/kg are identical, while GB is tighter on cadmium (0.002 versus 0.005 mg/kg). Both are release and migration instruments, and both are three to five orders of magnitude below the percent-by-weight composition caps used by the Korean MFDS and Japanese food-contact metal rules, which govern substrate content rather than release. Because CM/Res(2013)9 is a resolution rather than directly-applicable law, this wiki treats a binding national instrument as the sovereign maximum level and CM/Res(2013)9 as comparator context.
Sources
- Council of Europe Resolution CM/Res(2013)9 and the EDQM Technical Guide “Metals and alloys used in food contact materials and articles,” Article 4, Table 1 and Table 2. Local copy:
raw/regulatory/coe/coe-cm-res-2013-9-metals-alloys.pdf. - EDQM publication page: https://www.edqm.eu/en/metals-and-alloys-used-in-food-contact-materials-and-articles
Update history
This page has no substantive edit history yet. Future revisions will be recorded here once the change lands in git.