Metals and alloys used in food contact materials and articles: a technical guide for manufacturers and regulators, 2nd edition

Overview

The EDQM / Council of Europe 2nd edition technical guide supplements Resolution CM/Res(2020)9 for food-contact materials and articles made from metals and alloys. It sets specific release limits (SRLs) in mg/kg food, summarizes safety reviews for alloy components and metal contaminants, and specifies release-testing approaches for foodstuffs and food simulants. This is regulatory context for metal food-contact materials rather than an occurrence study; its values are release limits and test-method instructions, not measured product concentrations.

Key numbers

• Publication identity: English edition ISBN 978-92-871-9436-7; French edition ISBN 978-92-871-9437-4; 2nd edition 2024; 232 PDF pages.
• Scope: the guide applies to unintentional release of metal ions from end-use materials and articles made completely or partly of metals and alloys, coated or uncoated, manufactured or imported into Europe, and intended or reasonably expected to contact food.
• Scope examples: household utensils, kitchen appliances, industrial processing equipment, food processors, wrapping, containers, pots, blenders, knives, forks, and spoons.
• Legal status: the guide supplements Resolution CM/Res(2020)9 and is intended to assist national policy-makers, enforcement authorities, manufacturers, and other business operators. It is not legally binding by itself.
• Generic rule from Resolution CM/Res(2020)9: unless otherwise specified, a generic SML or SRL of 60 mg/kg applies.

Table 1 SRLs for metals and alloy components

All SRLs are copied as mg/kg food.

Table notes: for chromium(VI), the guide points readers to the chromium safety-review section rather than setting a Cr(VI) SRL in Table 1. For silver cutlery, Chapter 3 Annex II describes a reduction factor. For tin, the guide notes an exception in the field of application under Commission Regulation (EU) 2023/915. For magnesium and titanium, the guide says the generic 60 mg/kg food SRL is not applicable.

Table 2 SRLs for metals as contaminants and impurities

All SRLs are copied as mg/kg food.

• Revision highlights in the foreword: chromium SRL set at 1 mg/kg (former limit 0.250 mg/kg); manganese SRL set at 0.55 mg/kg (former limit 1.8 mg/kg); thallium SRL corrected to 0.001 mg/kg (former limit 0.01 mg/kg); zirconium added with SRL 2 mg/kg.
• Arsenic recommendation: the guide sets the SRL for arsenic at 0.002 mg/kg food or food simulant, derived using the lower end of the EFSA 2009 BMDL01 range for inorganic arsenic and a 10% allowance for an impurity in metallic material.
• Lead recommendation: Table 2 sets lead at 0.010 mg/kg food. The guide discusses lead as a contaminant/impurity in metals and alloys, including tin coatings and pewter context.
• Cadmium recommendation: Table 2 sets cadmium at 0.005 mg/kg food. The guide notes that galvanised utensils may release zinc and cadmium.
• Mercury recommendation: Table 2 sets mercury at 0.003 mg/kg food.
• Stainless-steel context: the guide reports that no particular health concerns were raised by several studies of metal release in various media and foods cooked in stainless-steel pans, while noting that compliance with SRLs helps reduce risks from stainless steels that are not well known or individually tested.

Methods (brief)

Chapter 3 specifies release testing for metal and alloy food-contact materials. Tests into actual foodstuffs should be used when the article is already in contact with food, when intended use with a specified food is clear, or when normal-use abrasion or harsh conditions cannot be reproduced with liquid simulants. When food simulants are used, the guide recommends artificial tap water (EN 16889) for aqueous, alcoholic, or fatty food and 0.5% (m/v) citric acid for acidic foods with pH <= 4.5. Repeated-use articles not yet in contact with food should be tested three times in succession; compliance is based on the third test, and the sum of the first and second tests should not exceed 7 x SRL. Packaging materials should be sampled by batch size: <= 59 packages at least 3, 60-200 at least 5%, and > 200 at least 10; non-packaging kitchen utensils should have at least three replicated samples. Analytical methods must be validated under the Regulation (EU) 2017/625 framework and related EUR 24105 guidance.

Related evidence

• Cans/lids
• Foils/wraps
• Metal and alloy cookware (cast iron, stainless steel, aluminum)
• Specialty alloy cookware (copper, carbon steel)
• Metal bottles/tumblers
• Metal utensils
• Bakeware
• Kettle interiors
• Blender jars
• Food processor bowls
• Aluminum
• Antimony
• Arsenic, Total
• Barium
• Beryllium
• Cadmium
• Chromium
• Cobalt
• Copper
• Iron
• Lithium
• Magnesium
• Manganese
• Mercury, Total
• Molybdenum
• Nickel
• Silver
• Tin
• Titanium
• Thallium
• Vanadium
• Zinc
• EU Regulation 2023/915 maximum levels for contaminants in food

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