May 16, 2025
Starting January 1, 2025, the Netherlands State Secretary for Health, Welfare and Sport implemented a Regulation amending the Packaging Commodities Act Regulation and consumer articles on materials and articles of metal and alloy intended to be used in contact with food.
These migration limits shall be observed for the following substances used in metallic food contact materials:
| SUBSTANCE | LIMIT (mg/kg) |
| Arsenic | 0.002 |
| Cadmium | 0.005 |
| Chromium | 0.25 |
| Cobalt | 0.02 |
| Copper | 4 |
| Lithium compounds (as lithium) | 0.048 |
| Manganese | 1.8 |
| Vanadium | 0.01 |
Furthermore, the following substances with corresponding Specific Migration Limits (SML) are added:
| SUBSTANCE | LIMIT (mg/kg) |
| Barium | 1.2 |
| Beryllium | 0.01 |
| Iron | 40 |
| Mercury | 0.003 |
| Molybdenum | 0.12 |
| Thallium | 0.0001 |
| Tin | 100 (unless otherwise provided in Commission Regulation (EU) 2023/915) |
| Silver | 0.08 |
The Ministerial Regulation requires that a written declaration in accordance with the EU’s Food Contact Materials (FCM) Regulation shall be made available by the operator.
These changes are aligned with the Decision of the Benelux Committee of Ministers on metallic and alloy materials and articles intended to come into contact with foodstuffs (M (2022) 12). This decision is harmonized in the Netherlands, Belgium and Luxembourg.
This applies to packaging and consumer products in whole or in part made of metals or alloys that are coated or uncoated.
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