German BfR updated 10 recommendations concerning paper and board, silicones,ect

Recently, the German Federal Institute for Risk Assessment (BfR) issued Announcement No. 232, updating 10 recommendations on food contact materials. This update mainly concerns paper and board, silicones, polymer dispersions, thermoplastic elastomer vulcanizates (TPV), hard paraffins, microcrystalline waxes and natural waxes, acetal resins, fillers, etc. The new recommendations took effect on October 1, 2026.

The following are the updated recommendations and the main changes:

BfR Recommendation XXXVI-Paper and board for food contact

1.The following has been added to the preamble: “An investigation of substance migration in the extract of the finished products shall be conducted in accordance with the guidelines set forth in the Paper guideline and shall be based on the intended use of the paper.”

2.The following has been added to the preamble: “For certain genotoxic carcinogens that may occur, for example, as reaction and degradation products or impurities in the manufacture of food contact materials in accordance with this Recommendation—and for which migration into food should not be detectable—specific detection limits are specified in this Recommendation (e.g., certain primary aromatic amines or 1,3-dichloro-2 -propanol). No measurement uncertainty is to be applied . The specified detection limits correspond to the current technical standard. They are regularly reviewed to ensure they remain up to dateand, where possible, are further reduced. The goal is to ensure that no migration of genotoxic carcinogens exceeding 0.15 μg/kg of food is detectable.”

3.Added and revised some permitted substances or their restrictions.

4.Due to the PFHxA entry under the EU REACH Regulation and the requirements of the PPWR, 13 PFAS previously permitted for use in surface refining and coating agent have been deleted.

5.Footnote 4: The original reference to Table 2 of (EU) No 10/2011 is clarified as Table 2 of Annex III to (EU) No 10/2011.

6.Footnote 17: The water extract is specified as “cold water extract”; for all products except kitchen paper towels, the detection limit for non-detectable 1,3-dichloro-2-propanol is lowered from “2 µg/L” to “1 µg/L”, while the limit for kitchen paper towels remains 2 µg/L.

7.Footnote 30: Rephrased as: “A transfer of the cationizing agents 3-chloro-2-hydroxypropyltrimethylammonium chloride or glycidyltrimethylammonium chloride into the food must not be detectable . The detection limit is 2 μg/kg . The transfer of the reaction product 2,3-dihydroxy-N,N,N-trimethyl-1-propanaminium chloride (CAS 34004-36-9) to food must not exceed 5 mg/kg .The transfer of the reaction product (1E)-3-hydroxy-N,N,N-trimethyl-1-propen-1-aminium chloride (CAS 91725-36-9)to food must not exceed 0.05 mg/kg.”

BfR Recommendation XXXVI/1-Cooking Papers,Hot Filter Papers and Filter Layers

1.Content related to certain genotoxic carcinogens has been added to the preamble.

2.Added and revised some permitted substances or their restrictions.

3.Footnote 17: Rephrased. (Same as Footnote 30 of BfR Recommendation XXXVI)

BfR Recommendation XXXVI/2-Paper and Paperboard for Baking Purposes

1.Content related to certain genotoxic carcinogens has been added to the preamble.

2.Deleted and revised some permitted substances or their restrictions.

3.Due to the PFHxA entry under the EU REACH Regulation and the requirements of the PPWR, 3 PFAS previously permitted for use in surface refining agents for the food-contact surface have been deleted.

4.Footnote 11: Rephrased. (Same as Footnote 30 of BfR Recommendation XXXVI)

BfR Recommendation XXXVI/3-Absorber pads based on cellulosic fibres for food packaging

1.Content related to certain genotoxic carcinogens has been added to the preamble.

2.Revised the restrictive requirements for some permitted substances.

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 attention to this update and promptly ensure the compliance of related products.