SG 081/25
Denmark has completed a public consultation over the nation’s proposed law on food contact materials (FCMs) and articles. If approved, the law will become effective on January 1, 2026.
In April and May 2025, the Danish Veterinary and Food Administration (DVFA, Fødevarestyrelsen) consulted on its draft Executive Order on Food Contact Materials and Penal Provisions for Violations of Related EU legislation’ (Draft Order).
Highlights of the Draft Order are summarized in Table 1
| Section to Draft Order | Highlights |
|---|---|
| § 1 ‘Application Area’ |
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| § 2 ‘Definitions’ |
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| § 5 ‘DoC’ |
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| § 6 ‘Special measures for certain FCM’ |
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| § 7 ‘Regenerated cellulose film’ |
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| § 10 ‘Ceramic and enameled articles and glassware’ |
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| § 12 ‘Paper and cardboard’ |
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| § 14 ‘Penal provisions’ |
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| Annexes |
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Table 1
| Article1 | Lead | Cadmium |
|---|---|---|
| Category A: | ||
| 1. Articles that cannot be filled | ≤ 0.3 µg/dm2 | ≤ 0.4 µg/dm2 |
| 2. Articles which cannot be filled and articles which can be filled, the internal depth of which, measured from the lowest point to the horizontal plane passing through the upper rim, does not exceed 25 mm (flatware) | ||
| 3. The rim of articles intended for drinking2,3 | ||
| Category B: | ||
| Baby bottles | ≤ 1.5 µg/L | ≤ 0.35 µg/L |
| Articles intended for drinking3 | ≤ 0.70 µg/L | |
| Other articles that can be filled | ≤ 2.0 µg/L | |
| 1When an article is provided with a lid, the container alone and the inner surface of the lid must be tested separately. The sum of the released amounts of lead or cadmium (µg) is related to the volume of the article (L) (however, the surface area of a Category A article is in dm2) 2Migration from 20 mm area measured from the top rim of articles intending for drinking 3Migration must meet the requirements for both Category A (release from rim) and Category B | ||
Table 2. Annex 5 ‘Limit values for lead and cadmium from ceramic and enameled articles and glassware’ as per Draft Order
The Draft Order is planned to enter into force on January 1, 2026, and will repeal Executive Order No 681 of May 25, 2020, on FCMs and Criminal Provisions for Infringements of Related Union Acts’.
Food contact ceramic and enameled articles and glassware that do not meet the requirements of Section 11, but which comply with Section 4 and were placed on the market before January 1, 2026, may remain on the market until stocks are exhausted.
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