Germany’s BfR Revises Recommendations for Food Contact Materials

SafeGuardSHardgoodsOctober 21, 2025

SG 154/25

The German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) has updated several recommendations for nine different types of food contact material (FCM) and article.

The BfR has recently issued eight revised recommendations and withdrawn one recommendation for a variety of FCMs and articles.

Key changes to these nine recommendations (in German or English) are summarized in Table 1.

Item	Recommendation as of October 1, 2025	Highlight
1	XIV ‘Polymer dispersions’	When compared to its February 2022 version: Expands the list of emulsifying agents to include sodium hexametaphosphate with specifications Introduces Category 3 ‘Additives’ with requirements for microfibrillated cellulose
2	XV ‘Silicone’	When compared to its September 2024 version: Revises footnote 7 to ‘The waxes and paraffins must comply with Recommendation XXV ‘Hard paraffins, microcrystalline waxes and their mixtures with waxes, resins and plastics, and natural waxes, Part 1’
3	XVII ‘Polyterephthalic acid diol esters	When compared to its July 2016 version: Adds footnote 1 with ≤ 2% 4,4’-dioxydiphenyl-2,2-propane (bisphenol A diglycidyl ether) and emphasizes that Regulation (EU) 2024/3190 on bisphenol A (BPA) and other bisphenols and bisphenol derivatives must be observed (SafeGuardS 5/25)
4	XXX ‘Conveyor belts made from gutta-percha and balata’	Withdraws (current) 1984 version of this recommendation with no replacement
5	XXXVI ‘Paper and board for food contact’	When compared to its August 2024 version: Replaces footnote 8 with ‘a gray scale 5 must be achieved using EN 646, and details of BfR’s Collection of methods for paper, cardboard and paperboard’ New footnote 9 indicating that an assessment level 5 must be achieved using EN 648, and details of BfR’s Collection of methods for paper, cardboard and paperboard Introduces ‘Not Detected (ND, Detection Limit (DL) = 0.01 mg/kg) acrylamide release’ from finished product (preamble point 14) Expands the number of entries with specifications under fibrous materials, production aids and special paper refining agents Repositions footnote 8 on primary aromatic amines (PAA) to footnote 10 with new text Strengthens BPA migration in recycled paper from 0.05 mg/kg to 0.01 mg/kg (Annex) Introduces footnote 36 for mineral oil aromatic hydrocarbons (MOAH)
6	XXXVI/1 ‘Cooking paper, hot filter paper and filter layers’	When compared to its August 2024 version: Introduces ‘ND (DL = 0.01 mg/kg) acrylamide release’ from finished product (preamble)
7	XXXVI/2 ‘Paper and paperboard for baking purposes’	When compared to its August 2024 version: Introduces ‘ND (DL = 0.01 mg/kg) acrylamide release’ from finished product (preamble)
8	XXXVI/3 ‘Absorber pads based on cellulose fibers for food packaging’	When compared to its September 2019 version: Introduces ‘ND (DL = 0.01 mg/kg) acrylamide release’ from finished product (preamble)
9	XLIV ‘Artificial sausage casings’	When compared to its November 2014 version: Revises footnote 10 to ‘The waxes and paraffins must comply with Recommendation XXV ‘Hard paraffins, microcrystalline waxes and their mixtures with waxes, resins and plastics, and natural waxes, Part 1’

Table 1

These nine updated recommendations became effective on October 1, 2025.

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