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GERmany: Proposal in amending aromatic mineral oil hydrocarbon requirement in recycled food contact paper


German Federal Ministry of Food and Agriculture drafted the amendment of Consumer Goods Ordinance1 in order to limit the migration of aromatic mineral oil hydrocarbon (MOAH) from recycled paper to food. The European Commission received a notification for this draft and collects comments until 18 November 2020.

Proposed requirement 
The draft introduces the use of functional barriers to ensure that no MOAH is transferred from the food contact materials to the foodstuff. The functional barrier can be in various forms, such as film, coating or intermediate bags. It can be permanently connected or be separated from the food contact materials. It may be made by metal (e.g. aluminium) or plastic (e.g. polyester) which depends on the final product forms. 
Food contact material operators (e.g. manufacture, distributor) should equip a functional barrier for the recycled paper food contact material. It is to ensure there is no MOAH transferred to food. The functionality of the barrier is determined by testing with suitable food simulants and the corresponding detection limit is 0.15 mg of MOAH per kg of food simulant. Otherwise, the limit of 0.5 mg of MOAH per kg of food should be applied by testing with food. 

Measures other than functional barriers
If food business operators (procuring the food contact material) can take measure to ensure no MOAH is transferred to food “(e.g. Transfer from MOAH to food does not take place or is not above the detection limit for certain nature of food (e.g. table salt) or under certain conditions of use (e.g. Frozen food or short -term contact with dry food), they can declare to manufacturers or distributors that a functional barrier is not required. If manufacturers or distributors can guarantee no MOAH transferred from their food contact material to food without using a functional barrier (e.g. It is proved that the MOAH content transferred is lower than the detection limit – 0.15 mg/kg by applying simulant test), a functional barrier is not required.

Transition period
The date of official publication is not confirmed. However, the draft text mentioned it may enter into force on the day following its promulgation. The provision may be applied after 3 years transition period and the food contact materials manufactured before the date of application of provisions by Ordinance may be placed on the market and used for further 2 years after this date.

[1]  Notification for Draft amendment of Consumer Goods Ordinance

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