The Federal Public Service of Health, Food Chain Safety and Environment of Belgium has proposed a decree on food contact materials and articles made of metals and alloys.

Scope

The decree shall apply to food contact materials and articles which are wholly or partly made of metals and/or alloys, whether or not covered with surface coating.

General requirements

Metal and alloy food contact articles shall comply with the following regulations:

1. Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food
2. Commission Regulation (EC) No 2023/2006 on good manufacturing practices for materials and articles intended to come into contact with food
3. Belgian Royal Decree of 11 May 1992 concerning materials and articles intended to come into contact with food

Specific requirements

1. Specific migration requirements

a. Products shall comply with the specific migration limits stated in Chapter 1 of Annex to the Decree:

Table 1: Specific migration limits applicable to metals and alloy components

* Except for cases covered by Regulation (EC) No 1881/2006 on maximum levels for certain contaminants in foodstuffs

Table 2: Specific migration limits applicable to metals in the form of contaminants and impurities

b. The specific migration limits shall be verified by national and/or European test methods. 

c. The specific migration values shall be expressed in mg/kg applying the real surface area to volume ratio in actual or foreseen use. By way of derogation, sheets, film and flat surfaces which are not yet in contact with food, the migration value shall be expressed in mg/kg applying a surface to volume ratio of 6 dm2 per kg of food.

2. Nanomaterials

Substances in the form of nanoparticles shall require a specific evaluation of their properties, the intended use and the measurement of exposure in case of release into food.

3. Declaration of conformity

Products shall be accompanied by a declaration of conformity, containing the information listed in Chapter 2 of the Annex to the Decree [Note: Declaration for products that are not considered as final products shall provide information in points (a), (b), (c) and (e) at least]:

1. Identity and address of the business operator who manufactures or imports the materials and articles or the substances intended for the manufacture of these materials and articles;
2. Identity of metals and alloys for the manufacture of materials and articles;
3. Date of the declaration;
4. Confirmation of conformity of materials and articles with the applicable requirements of the Decree and Regulation (EC) No 1935/2004;
5. Adequate information relative to the metals used for which the restrictions and/or specifications set out in the Decree are in place to enable downstream business operators to ensure compliance with those restrictions;
6. Adequate information on restricted metals in foods obtained from experimental data or theoretical calculation about their specific migration level;
7. Specifications concerning the use of the material or article, such as:
   i) Type (s) of food intended to be in contact with them;
   ii) Duration and temperature of treatment and storage in contact with the food;
   iii) Surface/volume ratio in contact with the food used to establish conformity of the material or article

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