The Netherlands Revises Requirements for Food Contact Metals and Alloys

SafeGuardSHardgoodsApril 10, 2025

SG 054/25

The Netherlands has strengthened its specifications for food contact metals and alloys under its Commodities Act. The regulation became effective in January 2025.

In December 2024, the Netherlands published Regulation of the State Secretary for Health, Welfare and Sport of December 19, 2024, reference number 3976782-1072880-WJZ (the Amendment) to amend the requirements for food contact metals and alloys under the nation’s Commodities Act on Packaging and Consumer Articles (Commodities Act, version valid from January 2025 to present).

Highlights of the amendment are summarized in Table 1. It is interesting to note that the specific release limit values for chromium and manganese have become less stringent.

Chapter/Section to Part A of Annex to the Commodities Act	Highlights of change
Chapter IV ‘Metals’ Paragraph 1 ‘Description’	Adds a definition for ‘alloy’ Emphasizes that this chapter applies to packaging and consumer articles made wholly or partly of metals or alloys, whether coated or uncoated
Chapter IV ‘Metals’ Table to §4.3 ‘Specific migration’	Amends the specific release requirements for the following substances: ≤ 0.002 mg/kg arsenic (from 0.01 mg/kg) ≤ 0.005 mg/kg cadmium (from 0.01 mg/kg) ≤ 0.25 mg/kg chromium (from 0.1 mg/kg) ≤ 0.02 mg/kg cobalt (from 0.05 mg/kg) ≤ 4 mg/kg copper (from 5 mg/kg) ≤ 0.048 mg/kg lithium compounds, total (as lithium) (from 0.6 mg/kg) ≤ 1.8 mg/kg manganese (from 0.6 mg/kg) ≤ 0.01 mg/kg vanadium (from 0.05mg/kg)
Chapter IV ‘Metals’ Table to §4.3 ‘Specific migration’	Adds the specific release requirements for the following substances: ≤ 1.2 mg/kg barium ≤ 0.01 mg/kg beryllium ≤ 40.0 mg/kg iron ≤ 0.003 mg/kg mercury ≤ 0.12 mg/kg molybdenum ≤ 0.0001 mg/kg thallium ≤ 0.08 mg/kg silver ≤ 100 mg/kg tin, unless otherwise indicated in Regulation (EU) 2023/915
Chapter IV ‘Metals’ §4.9 ‘Requirements for finished product’	Mandates a written declaration of conformity (DoC) in accordance with Article 16 of Regulation (EC) 1935/2004 (current consolidated version to March 2021) and paragraph 0.9 of Chapter 0, Part A to Annex of the Commodities Act

Table 1

The amendment took effect on January 1, 2025 – the day following its publication in the Government Gazette

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