ConsumerMail 07 - Food contact plastic and lead migration limits

ConsumerMail 07 - Food contact plastic and lead migration limits

Posted 22 May 2017
This issue of ConsumerMail look at the Council of the European Union Commission Regulation (EU) No 10/2011 (2) that lays down specific rules regarding plastic materials and articles intended to come into contact with foods, as well as the adopted Directive (EU) 2017/738 to amend the lead migration limits for toys under Toy Safety Directive (TSD) 2009/48/EC.
Download a PDF of ConsumerMail 07

EU - Reinforcement of Chemical Safety in Food Contact Plastic

Commission Regulation (EU) No 10/2011 (2) lays down specific rules regarding plastic materials and articles intended to come into contact with foods. Last update is August 2016 (EU 2016/1416).

This time (EU 2017/752) is the reinforcement of chemical safety in food contact plastics.  This amendment will be implemented in two phases starting May 19, 2017.

Below are the important highlights:

  • Nickel, restricted to no more than 0.02 mg/kg in Annex II (For materials and articles) 
  • Added 6 substances to the authorized list of substances
  • Editorial changes to Table 3 (Choice of simulant) in point 4 to Annex III
  • Replacing the residual content of 10 substances with specific migration limits

There are two effective dates for this amendment: 

  • May 19, 2017 for Regulation (EU) 2017/752 (except for the specific migration of nickel falling under point 1 to Annex II)
  • May 19, 2019 for the specific migration of nickel falling under point 1 to Annex II.
Highlights of a comparison of the specific migration of heavy metals Regulation (EU) 10/2011 are summarized in the table below: 
Elements (EU) 2017/752 amending of (EU) 10/2011
(mg/kg)
(EU) 2016/1416 amending of (EU) 10/2011
(mg/kg)
(EU) 10/2011
(mg/kg)
1. Aluminum (Al) 1 1 Not restricted
2. Barium (Ba) 1 1 1
3. Cobalt (Co) 0.05 0.05 0.05
4. Copper (Cu) 5 5 5
5. Iron (Fe) 48 48 48
6. Lithium (Li) 0.6 0.6 0.6
7. Manganese (Mn) 0.6 0.6 0.6
8. Zinc (Zn) 5 5 25
9. Nickel (Ni) 0.02 Not Restricted Not restricted
Effective Date: May 19, 2019 September 14, 2018 May 2011

EU – Amendment to Lead Migration Limit under TSD

The Council of the European Union has adopted Directive (EU) 2017/738 to amend the lead migration limits for toys under TSD- Toy Safety Directive 2009/48/EC.

It is for last year’s proposed draft on a lead limit. Member States shall apply the new requirements from 28 October 2018.

In point 13 of part III of Annex II to the Toy Safety Directive, the lead migration limits for different toy materials shall be revised as follows:

Element Dry, Brittlle, Powder-Like or Pliable Toy Material Liquid or Sticky Toy Material Scraped-Off Toy Material
Lead Current limit (mg/kg) 13.5 3.4 160
New limit (mg/kg) 2.0 0.5 23

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