On local time, the German Federal Institute for Risk Assessment (BfR) issued Announcement No. 232, updating 10 food contact materials (FCM) recommendations in a single update. The revised documents will officially take effect on October 1, 2026. This revision covers seven major categories: paper and cardboard, silicone, polymer dispersions, TPV thermoplastic vulcanizate, waxes, aldehydes, and fillers. Among them, the food contact paper and cardboard series (XXXVI series) serves as the core focus of this revision. Three major changes—zero detection of genotoxic carcinogens, the phase-out of PFAS permanent chemicals, and significantly tightened diacetyl indicators—will profoundly alter the compliance logic for domestic food packaging paper, baking paper, oil-absorbent pads, filter paper, and other products exported to the EU.
First, it should be noted that the BfR opinion is not part of the unified mandatory regulations of the European Union, but it holds binding force in the German market. It also serves as a key technical reference for laboratories and importers in EU member states when assessing the safety of food contact materials, making it a crucial indicator for the safety management of food contact materials within the EU.
This time, the BfR XXXVI series of recommended specifications for food contact paper and cardboard have been revised, with a focus on adjusting the paper and cardboard section. The control strength has been significantly improved, and the applicable categories include ordinary food packaging paper, baking paper, cooking filter paper, and fresh cellulose absorbent pads. Revise and unify the principles for controlling genotoxic carcinogens, linking with the EU REACH regulation PFHxA restriction clause and PPWR packaging regulation, and phasing out PFAS permanent chemicals as oil proof functional raw materials.
BfR XXXVI Food Contact Paper and Paperboard
The migration detection plan has been revised: a pre explanation clause has been added, and the substance migration testing of finished product extracts must be carried out in accordance with the BfR paper special guidelines. The testing conditions should be differentiated according to the predetermined contact scenarios of the product, and food simulants corresponding to hot contact, high-fat, and water containing foods should be distinguished. The unified standardized testing mode should be cancelled. Establish a zero detection control principle for genotoxic carcinogens: aromatic amines, 1,3-dichloro-2-propanol and other process impurities, as well as the migration of degradation products of genotoxic carcinogens, shall not be detected; Compliance determination does not allow the use of measurement uncertainty exemptions or tolerance values. Once detected, non-compliance is determined; The detection limit will continue to decrease with the advancement of analytical technology, with a long-term goal of 0.15 μ g/kg, consistent with the TTC toxicological concern threshold set by the EU EFSA for genotoxic substances. Simultaneous supplementation and revision of the list of licensed substances and restrictive clauses.
Batch removal of PFAS substances: In order to meet the requirements of REACH PFHxA control and PPWR packaging regulations, 13 perfluorinated/polyfluorinated substances used for surface coating and oil repellent treatment in the list have been removed. The traditional process scheme with PFAS as the core oil repellent component no longer meets compliance requirements. Revise the index expression of (EU) No 10/2011: clarify the citation relationship of the original footnotes and clarify that Table 2 corresponds to Appendix III Table 2 of (EU) No 10/2011.
Stricter limit for 1,3-DCP: The testing medium is uniformly defined as cold water extract, which matches the actual scenario of food contact at room temperature; The detection limit for kitchen tissues remains at 2 μ g/L, while the detection limit for other paper products has been lowered from 2 μ g/L to 1 μ g/L. Refined control of by-products of cationic wet strength additives in papermaking: migration of raw material 3-chloro-2-hydroxypropyltrimethylammonium chloride should not be detected (detection limit 2 μ g/kg); Exclusive migration limits are set for two by-products: 2,3-dihydroxy-N, N, N-trimethyl-1-propylammonium chloride ≤ 5 mg/kg; (1E) -3-hydroxy-N, N, N-trimethyl-1-propen-1-ammonium chloride ≤ 0.05 mg/kg.
BfR XXXVI/1 Cooking paper, hot filter paper and filter layer
Control objects: coffee filter paper, tea hot filter layer, cooking oil filter paper.
Add regulations on the control of genotoxic carcinogens in the preface;
Update the list and limits of substances allowed for use;
Inherit all provisions of XXXVI cationic additive by-product migration control.
BfR XXXVI/2 Baking paper and cardboard
Key export high-risk products: air fryer paper, oven baking oil paper, and oil resistant baking cardboard.
Preface: Supplement requirements for the control of genotoxic carcinogens;
According to REACH PFHxA and PPWR regulations, remove three PFAS substances from the list of surface treatment agents for food contact surfaces;
Adjust the list of permitted substances and synchronously implement the migration limit of cationic auxiliary by-products.
BfR XXXVI/3 cellulose fiber absorbent pad
Applicable objects: Fresh food tray absorbent pad, meat packaging absorbent pad.
Introduction: Added control measures for genotoxic carcinogens;
Update the list of licensed substances and limit indicators.
