German BfR updates several food contact recommendations - rubber, TPV

Recently, the German Federal Institute for Risk Assessment (BfR) issued Announcements No.230 and No.231, updating several recommendations on food contact materials. The updates mainly concern rubber materials, and for the first time, a recommendation on thermoplastic elastomer vulcanizates (TPV) has been published. The new recommendations took effect on June 1, 2026.

The following are the recommendations updated this time:

BfR Recommendation XXI/3-Consumer goods made of thermoplastic elastomer vulcanizates (TPV)

1.Scope: This recommendation applies to consumer goods made of thermoplastic elastomer vulcanizates (TPV) which, in accordance with their intended use,come into contact with food.

2.Definition of thermoplastic vulcanizates (TPV): Polymers consisting of a blend of a thermoplastic material and a conventional rubber,in which the rubber has been cross-linked by the dynamic vulcanisation process during the blending and mixing process.

3.Migration and restrictions on use: Migration conditions and the classification of categories in accordance with Recommendation XXI/1 shall apply.The test shall be carried out on the finished cross-linked TPV.

4.Raw material requirements:

●Thermoplastic components: With regard to the use of starting materials (monomers)and additives or processing aids for the thermoplastic component of TPV,the provisions of Regulation (EU)No 10/2011 apply. However,this Recommendation XXI/3 applies only to TPVs whose thermoplastic component consists of the monomers listed in Table 1.

●Rubber components: Starting materials,additives and processing aids in accordance with Recommendations XXI and XXI/1 may be used. The respective application restrictions and notes must be observed.

●Cross-linking agents: Cross-linking agents that may be used are listed in Table 1 of this Recommendation XXI/3. The cross-linking agents in Table 1 are temporarily permitted for use until 31 May 2029. Thereafter, substances that have been re-evaluated will be transferred to Recommendation XXI.

5.Finished products requirements：

In addition to the requirements and specifications already mentioned in the individual sections and in Recommendation XXI/1, finished products made from TPV must not show any positive reaction to peroxide on their surface.

CTT proposal

Although the BfR recommendations are not legally binding, they are widely recognized by the industry and serve as an important reference for products entering the German market. Relevant companies are advised to pay close attention to these updates and begin compliance work for TPV products intended for food contact as soon as possible.