SGS, the world’s leading testing, inspection and certification company, has published SafeGuardS 154.25 to inform stakeholders that Germany’s Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) has updated several recommendations for food contact materials (FCMs) and articles.
Effective October 1, 2025, the BfR issued eight revised recommendations and withdrew one, covering nine categories of materials and products. The updates introduce new compositional requirements, migration limits and references to recent European legislation, ensuring continued protection of consumer health and alignment with EU standards.
Among the changes, Recommendation XIV (Polymer dispersions) now includes sodium hexametaphosphate as an approved emulsifying agent and establishes a new additives category for microfibrillated cellulose. Recommendation XV (Silicone) and Recommendation XLIV (Artificial sausage casings) have been harmonized with Recommendation XXV regarding the use of waxes and paraffins. Updates to Recommendation XVII (Polyterephthalic acid diol esters) introduce new restrictions on bisphenol A diglycidyl ether (BADGE) and require compliance with Regulation (EU) 2024/3190 on bisphenols, further strengthening consumer protection.
A significant revision to Recommendation XXXVI (Paper and board for food contact) enhances testing rigor by introducing a ‘not detected’ acrylamide release limit of 0.01 mg/kg, reducing the permissible BPA migration level from 0.05 mg/kg to 0.01 mg/kg in recycled paper and adding new specifications for fibrous materials, production aids and refining agents. The same acrylamide release limit now also applies to Recommendations XXXVI/1, XXXVI/2 and XXXVI/3, covering cooking paper, baking paper and cellulose-based absorber pads. Meanwhile, Recommendation XXX (Conveyor belts made from gutta-percha and balata) has been formally withdrawn without replacement.
All nine updated recommendations took effect on October 1, 2025, reinforcing Germany’s commitment to ensuring food safety through robust materials regulation.
SGS publishes SafeGuardS to help stakeholders monitor evolving regulatory developments affecting materials intended for food contact. SafeGuardS 154.25 provides detailed insight into these BfR updates, supporting manufacturers and suppliers in maintaining compliance with national and EU FCM legislation.
Stakeholders are encouraged to review SafeGuardS 154.25 for comprehensive guidance on these recommendations.
SGS food contact material services
SGS’s technical experts have extensive experience of testing materials and articles in contact with food. They can ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. SGS offers the full range of testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. In the end, it’s only trusted because it’s tested. Learn more about SGS’s Food Contact Material Services.
SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full Germany’s BfR Revises Recommendations for Food Contact Materials SafeGuardS.
