Our coatings are frequently used on cooking and baking utensils and on other surfaces that come into contact with food. Many of our coating systems are designed to ensure that the finished product fulfils the numerous statutory and regulatory requirements for food contact materials in all major sales regions world wide.
EU Reg. 1935/2004 - Regulation on materials and articles in contact with food
In Europe, the most important regulation for food contact materials is EU VO 1935/2004. It provides a regulatory framework that covers all food contact materials, whether, for example, plastic, wood, ceramic or coated kitchen appliances. All items that may come into contact with food must be produced in such a way that the health of consumers is not jeopardized. This requirement is often implemented through national legislation and can be found in the German Food and Commodities Act (LFGB), paragraphs 30 and 31.
EU Reg. 10/2011 - Regulation on plastic materials and articles that have contact with food
The European Union has prescribed special rules for the various materials. So far, this has only taken the form of a positive list in the field of plastics, with Regulation 10/2011. For other materials that are also used in the coatings, specific regulations are yet to be adopted. The legal complexity and challenges increase layer by layer in the material mix; for example, in the case of cookware: Coating, metal or alloy, plastic, glass.
BfR LI - Recommendation for frying, cooking and baking equipment
Because there exists no European regulation for coatings, reference can be made to the national recommendation of the German Institute for Risk Assessment. For coatings, the LI Recommendation is especially relevant. If this recommendation has been adhered to, compliance with the EU's Framework Regulation 1935/2004 should be a given.
In this LI BfR recommendation, the operating temperatures of 230 °C resp. 250 °C are also indicated. Although most of the coatings exhibit higher temperature stability, the operating temperature is limited to the above-mentioned 230 °C resp. 250 °C.
In the regulations this is justified in stating that the food suitability must be checked and confirmed at the desired operating temperatures with a so-called food simulant. Since no food simulants are available that can withstand temperatures above 230 °C resp. 250 °C, testing is not possible at higher temperatures than those mentioned above. It is this clear that a higher operating temperature can not be stated.
Council of Europe - Resolution CM/Res (2013) 9 Metals and alloys
Since September 2013, a resolution for metals and alloys in contact with foodstuffs has been adopted by Europarat. http://www.edqm.eu/en/Metals-and-alloys-used-in-food-contact-materials-and-articles-1st-Edition-1582.html?mbID=137 . The resolution states limit values for the migration of various metal ions. In this respect, coatings can provide a supportive contribution in fulfilling these requirements. Compliance with these limits depends on the manufacturing process, the substrate materials used and the selected coating structure, and can therefore tests can only be carried out on the final product. We would be happy to assist you in choosing the right coating.
Our coating systems are intended for food contact after processing. The migration values depend, among other things, on all materials used and the processing conditions, and must therefore be tested on the finished product.
The migration test conditions of the product to be distributed to the consumer/customer can depend on the materials used and on the intended use . It is the responsibility of the manufacturer or the person who places the product on the market to check that the product complies with the regulations and is therefore suitable for sale.
In the USA, food contact materials fall within the scope of the FDA (Food and Drug Administration). http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm
There exists no special approval for coatings like in Europe. Although precise specifications regarding the applicable raw materials for some technical applications have been made in the Code of Regulations (CFR), household goods for personal use are exempted.
Please contact us to discuss any regulatory matter.
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