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Netherlands Amends Migration Limits for Certain Metals under its Packaging Regulation

Netherlands is amending its packaging regulation to align with European FCM regulation.

In December 2024, Netherlands issued the Regulation of the State Secretary for Health, Welfare and Sport(reference 3976782-1072880-WJZ), which amends the Packaging Commodities Act Regulation and consumer articles. The Amendment takes effect on January 1, 2025.

This amendment came under the Decision of the Benelux Committee of Ministers on Materials and Materials Articles of metal and alloy intended to be brought into contact with the (M (2022) 12), which represents the joint efforts by Benelux countries (Belgium, Netherlands and Luxembourg) to implement European FCM Resolution— CM/Res(2013)9 - Resolution on metals and alloys used in food contact materials and articleand harmonize it in these countries. 

Accordingly, the amendment brought in the concept of “alloy” and “metal” and is applicable to packaging and consumer products in whole or in part made of metals or alloys and coated or uncoated.

The specific migration limits (SML) for certain metals is established as follows:

Substance SML (mg/kg)
Arsenic0.002
Cadmium0.005
Chromium0.25
Cobalt0.02
Copper4
Lithium compounds, in total 0.048(as lithium)
Manganese1.8
Vanadium0.01
Barium1.2
Beryllium0.01
Iron40
Mercury0.003
Molybdenum0.12
Thallium0.0001
Tin100  (unless otherwise provided for in Regulation (EU) 2023/915)
Silver0.08

To demonstrate conformity, the operators shall provide a written declaration in accordance with Regulation (EC) No 1935/2004  on materials and articles intended to come into contact with food

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