METALS AND ALLOYS

used in food contact

materials and articles
A technical guide for manufacturers and regulators

European Committee EDQM

for Food Contact Materials 2nd Edition
and Articles (CD-P-MCA) 2024
 METALS AND ALLOYS
used in food contact
materials and articles
A technical guide for manufacturers and regulators

2nd Edition

European Directorate for the Quality of Medicines & HealthCare (EDQM)

French edition: Métaux et alliages
constitutifs des matériaux et objets pour
contact alimentaire,
ISBN 978-92-871-9437-4

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Contents

Foreword................................................................................................................... 7
Acknowledgements...............................................................................................9
Council of Europe Resolution CM/Res(2020)9 on the safety and
quality of materials and articles for contact with food............................. 11
Abbreviations used in this Technical Guide................................................ 27

Chapter 1 – General provisions and specific release limits

for metals........................................................................................................31
Introduction............................................................................................................31
Objectives................................................................................................................31
Involvement of national experts and stakeholders................................. 32
Legal status of the Technical Guide and link with the
European Union.................................................................................................... 32
Definitions, scope and specific release limits..............................................33
Updating of this Technical Guide and further provisions or
guidance.................................................................................................................. 39
References.............................................................................................................. 39

Chapter 2 – Safety review and recommendations................................. 41

Metals and alloy components.......................................................................... 41
Aluminium (Al)...................................................................................................... 43
Antimony (Sb).........................................................................................................53

3
 Chromium (Cr)....................................................................................................... 57
Cobalt (Co).............................................................................................................. 65
Copper (Cu).............................................................................................................69
Iron (Fe).....................................................................................................................75
Magnesium (Mg)....................................................................................................81
Manganese (Mn)................................................................................................... 85
Molybdenum (Mo)............................................................................................... 93
Nickel (Ni)................................................................................................................99
Silver (Ag)..............................................................................................................109
Tin (Sn)..................................................................................................................... 115
Titanium (Ti)..........................................................................................................123
Vanadium (V)........................................................................................................127
Zinc (Zn).................................................................................................................. 131
Zirconium (Zr).......................................................................................................137
Metal contaminants and impurities............................................................. 143
Arsenic (As)............................................................................................................145
Barium (Ba)............................................................................................................. 151
Beryllium (Be)........................................................................................................155
Cadmium (Cd).......................................................................................................159
Lead (Pb)................................................................................................................ 165
Lithium (Li).............................................................................................................173
Mercury (Hg).........................................................................................................177
Thallium (Ti)...........................................................................................................183
Stainless steels and other alloys.................................................................... 187
Alloys.......................................................................................................................187
Stainless steels..................................................................................................... 190

4
Chapter 3 – Release testing of food contact materials and articles
made from metals and alloys................................................................... 201
Criteria for the choice of test procedure.................................................... 201
Testing release from materials and articles into foodstuffs................. 201
Testing release from materials and articles into food simulants.......202
Sampling of materials and articles...............................................................204
Pre-treatment of materials and articles......................................................205
Release testing into foodstuffs......................................................................206
Release testing into food simulants.............................................................209
Methods of analysis............................................................................................213
Measurements and reporting........................................................................ 216
Calculation of specific release.........................................................................217
References............................................................................................................ 219
Annex I – Methods for measurement of articles for which
it is impractical to estimate the ratio of surface area to the
amount of foodstuff in contact with it........................................................221
Annex II – Correction factor applied when comparing release
test results for cutlery made from silver or silver-plated cutlery
with release limit for silver.............................................................................. 227

5
 

Foreword

Supplementing Council of Europe Resolution CM/Res(2020)9, this

Technical Guide is intended to ensure the safety and suitable quality of
food contact materials (FCM) and articles made from metals and alloys.
Chemical elements are described that constitute metallic food contact
articles or may be present as impurities, and specific release limits (SRLs)
have been set for those elements, where appropriate.

Information presented in this guide

• Resolution CM/Res(2020)9 on the safety and quality of materials
and articles for contact with food, defining guiding principles appli-
cable to FCM not yet harmonised by European material-specific
measures, such as coatings, paper and board and metals
• Chapter 1: Definitions, scope and specific release limits (SRLs) for
metals
• Chapter 2: Safety review and recommendations
• Chapter 3: Analytical methods for release testing of food contact
materials and articles made from metals and alloys
The guiding principles and technical recommendations are intended to
assist national policy makers and to enhance the harmonisation of techni-
cal standards across Europe.
The European Committee for Food Contact Materials and Articles
(CD-P-MCA) performed a comprehensive review of the first edition (2013)
of this Technical Guide to prepare the present edition.
This revision follows the adoption of Resolution CM/Res(2020)9 and takes
into account scientific opinions of EFSA issued since 2013, as well as relevant

7
Metals and alloys used in food contact materials and articles

publications by national risk assessment bodies (such as BfR, ANSES). The

review of safety data has resulted in the following changes:
• Chromium: the specific release limit (SRL) is set at 1 mg/kg (former
limit: 0.250 mg/kg)
• Manganese: the SRL is set at 0.55 mg/kg (former limit: 1.8 mg/kg)
• Thallium: the SRL was corrected to 0.001 mg/kg (former limit:
0.0001 mg/kg).
A new section on zirconium has been added and the SRL is set at 2 mg/kg.
Guidance on release testing has been updated to ensure coherence with the
Testing conditions for kitchenware articles in contact with foodstuffs: Plastics,
Metals, Silicone & Rubber or its revisions (Beldi et al., 2021).
The chapter on the declaration of compliance in the first edition was omitted
from the current edition in view of the corresponding guiding principles
stated in the Appendix to Resolution CM/Res(2020)9, section 8.2.

8
 

Acknowledgements

The second edition of this Technical Guide was prepared with the support
of the designated national representatives at the CD-P-MCA and other
contributors from the public and private sector, with expertise in rele-
vant fields such as analytical methodology and toxicology. They critically
reviewed the first edition as published in 2013 and also the relevant back-
ground information, recent scientific publications and legislation so that
substantial amendments could be made. Their contribution is gratefully
recognised and appreciated.
Substantial research was carried out by the Belgian experts (Federal Public
Service [FPS] Health, Food Chain Safety and Environment and Sciens-
ano Belgian Institute for Health) in their respective roles as rapporteur on
metals and alloys to the CD-P-MCA from 2018 and chair of the ad hoc
working group that was set up to address technical aspects of metal release
into food and food simulants. Tapping into the expertise of this ad hoc
group – composed of representatives not only from different manufacturer
federations, control laboratories and competent authorities but also pro-
ducers and consultants – relevant amendments were prepared for chapter 3
of the present guide.
Special thanks go to the German Federal Institute for Risk Assessment
(BfR) for the experimental work that laid the foundation for the revised
recommendations for release testing of food contact materials and articles
made from metals and alloys.
The revised Technical Guide was subject to a stakeholder consultation in
Spring 2022. The numerous comments received confirmed the wide inter-
est in the subject and guaranteed the high quality of the final text. Special

9
Metals and alloys used in food contact materials and articles

thanks are also due to the General Chemical State Laboratory of Greece
who co-ordinated the follow-up to the public consultation and consolida-
tion of the revised document in 2022.
And finally, this second edition would not have been possible without the
EDQM Secretariat, whose role in co-ordinating the revision, organising
expert meetings, translating relevant contributions and copy-editing the
Technical Guide is gratefully acknowledged.

10
 Council of Europe
Resolution CM/Res(2020)9
on the safety and quality of materials
and articles for contact with food

Adopted by the Committee of Ministers on 7 October 2020

at the 1385th meeting of the Ministers’ Deputies
 Resolution CM/Res(2020)9

The Committee of Ministers, in its composition restricted to the represent-

atives of the States Parties to the Convention on the Elaboration of a Euro-
pean Pharmacopoeia1 (“the Convention”),
Considering that the aim of the Council of Europe is to achieve greater
unity between its member States and that this aim may be pursued, inter
alia, by the adoption of common action in the health field;
Recalling that protection of health is a social human right and an essential
condition for social cohesion and economic stability;
Acknowledging the need to set quality and safety standards to minimise
the health risk posed to humans by certain material constituents when
released from materials or articles intended for contact with foodstuffs;
Considering that food contact materials and articles are also used in phar-
maceutical applications when the said materials are deemed suitable and
safe for that purpose;
Having regard to the opportunity to enhance synergies between the food
contact materials and articles and pharmaceutical sectors;
Following an approach similar to that published by the European Medi-
cines Agency (EMA) in the “Guideline on Plastic Immediate Packaging
Materials”, effective since 1 December 2005, which specifies that the pro-
visions of Community legislation on plastic materials and articles for food
contact should be taken into account, in cases indicated in the guideline;
Having regard to Regulation (EC) No. 1935/2004 of the European Par-
liament and of the Council of 27 October 2004 on materials and articles
intended to come into contact with food and specific EU measures for par-
ticular groups of food contact materials and articles adopted in accord-
ance with that Regulation, Commission Regulation (EC) No. 2023/2006
of 22 December 2006 on good manufacturing practice for materials and
articles intended to come into contact with food, Regulation (EU) 2017/625

1 States concerned [in 2020]: Albania, Austria, Belgium, Bosnia and Herzegovina,
Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France,
Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg,
Malta, Republic of Moldova, Montenegro, Netherlands, North Macedonia, Norway,
Poland, Portugal, Romania, Serbia, Slovak Republic, Slovenia, Spain, Sweden,
Switzerland, Turkey, Ukraine and United Kingdom.

13
Metals and alloys used in food contact materials and articles

of the European Parliament and of the Council of 15 March 2017 on official

controls and other official activities performed to ensure the application
of food and feed law, rules on animal health and welfare, plant health and
plant protection products, Regulation (EC) No. 852/2004 of the European
Parliament and of the Council of 29 April 2004 on the hygiene of food-
stuffs, Regulation (EC) No. 853/2004 of the European Parliament and of
the Council of 29 April 2004 laying down specific hygiene rules for food of
animal origin and Regulation (EU) No. 528/2012 of the European Parlia-
ment and of the Council of 22 May 2012 concerning the making available
on the market and use of biocidal products or relevant national legislation
which, although not binding for all of the States Parties to the Convention,
should nevertheless be taken into consideration;
Taking into account that the Technical Guides on food contact materials
and articles and resolutions are widely recognised and used as a reference
for the safety, quality and use of coatings, colorants, cork, glass, metals,
paper and board, plastics, printing inks for food contact materials, resins for
adsorption and ion exchange and elastomers such as rubber and silicones;
Taking into account that Resolution CM/Res(2013)9 and the applicable
Technical Guide on metals and alloys used in food contact materials and
articles are widely recognised and used as a reference for the safety and
quality of such materials and articles;
Being convinced that each member State would benefit from harmonised
state-of-the-art quality requirements and test procedures, described in the
Technical Guides and published under the aegis of the EDQM,
Recommends to the governments of States Parties to the Convention that,
in the absence of the specific measures referred to in Article 5 of Regula-
tion (EC) No. 1935/2004, they adopt suitable legislative and other measures
aimed at reducing the health risks arising from human exposure to constit-
uents released from materials or articles for contact with food according to
the appended “Guiding Principles for food contact materials and articles”
and the Technical Guides published under the aegis of the EDQM to sup-
plement this resolution. Likewise, in cases considered appropriate by the
national competent authorities, the Committee of Ministers recommends
that they apply these principles to materials and containers for pharma-
ceutical use in the absence of dedicated standards. This resolution shall not

14
 Resolution CM/Res(2020)9

prevent governments from maintaining or adopting national measures that

implement stricter or different rules and regulations.
Agrees that the CD-P-MCA, taking into account scientific or regulatory
developments or needs, will update, as necessary, the appendix “Guiding
Principles for food contact materials and articles” and the Technical Guides,
published under the aegis of the EDQM to supplement this Resolution.

15
Metals and alloys used in food contact materials and articles

Appendix: Guiding principles for food contact

materials and articles

1. Purpose and Scope

Resolution CM/Res (2020)9, its Guiding Principles and the supplemen-
tary Technical Guides contribute to the protection of human health by
ensuring, as defined in relevant European legislation, i.e. Regulation (EC)
No. 1935/2004, the safety and quality of food contact materials and arti�-
cles that are not covered by specific European legal provisions or other
measures, e.g. at the European Union (EU) level. The resolution therefore
complements European legislation taking into account Council of Europe
member States’ legislations or recommendations. This appendix provides
general guidance, e.g. on the use of substances in the manufacture of food
contact materials and articles, labelling of these materials and articles and
the need for a declaration of compliance and supporting documentation.
It applies to all food contact materials and articles under the scope of the
resolution. The Technical Guides specify the requirements (or derogations
from the principles stated hereafter) for particular types of materials, such
as paper and board or metals, and testing.

2. Definitions
The definitions of Regulation (EC) No. 1935/2004 and, where appropriate,
of Regulation (EU) No. 10/2011, apply in the context of the resolution, the
Guiding Principles and the applicable Technical Guides.
In addition, the following definitions apply:
• Food contact: direct (physical) contact or indirect (through the gas phase
or through different packaging components or layers in a multi-layer
material) contact of a food contact material or article with a food.
• Officially evaluated substances: substances for which risk assessment has
been carried out according to the principles stated under section 4, by a
competent authority of a Council of Europe member State or a relevant
European authority.

16
 Resolution CM/Res(2020)9

• Overall release limit (ORL) or overall migration limit (OML):2 the

maximum permitted amount of non-­volatile substances released from a
material or article into food simulants.
• QM: the maximum permitted quantity of a substance in the final mate-
rial or article expressed as mass per mass concentration.
• QMA: the maximum permitted quantity of a substance in the final
material or article expressed as mass per surface area in contact with
food.
• (Quantitative) structure-activity relationship models ((Q)SAR models):
theoretical models that can be used to quantitatively or qualitatively
predict the physicochemical, biological (e.g. an (eco) toxicological
endpoint) and environmental fate properties of compounds from the
knowledge of their chemical structure.3
• Specific release limit (SRL)4 or specific migration limit (SML): the
maximum permitted amount of a given substance released from a mate-
rial or article into food or food simulants.

3. General Requirements
Food contact materials and articles shall comply with Regulation (EC)
No. 1935/2004 and Regulation (EC) No. 2023/2006, or with relevant national
legislation. Under normal or foreseeable conditions of use, they shall not
transfer their constituents to food in quantities which could:

2 The term ‘OML’ is especially used in connection with polymeric materials (e.g.
plastics), whereas the term “release” is understood to designate any mechanism of
substance transfer from a food contact material and article to food. In the context
of these Guiding Principles the general term ‘release’ is used for substance transfer
from food contact materials and articles to food, including polymeric materials.
3 Practical Guide – How to use and report (Q)SARs, ISBN: 978-92-9247-809-4,
European Chemicals Agency, 2016. Available online at https://echa.europa.eu/
documents/10162/13655/pg_report_qsars_en.pdf.
4 The term ‘SRL’ was introduced in the context of metals and alloys used in food
contact materials. Whereas the more general term ‘release’ may be applied to various
materials, the term ‘migration’ is especially used in connection with polymeric
materials (e.g. plastics), where release is commonly dominated by physical processes
such as diffusion.

17
Metals and alloys used in food contact materials and articles

a. endanger human health; or

b. bring about an unacceptable change in the composition of the food; or
c. bring about a deterioration in the organoleptic characteristics thereof.
In addition, food business operators shall ensure that they use food contact
materials and articles during food production or preparation, storage and
distribution in a way that does not compromise compliance with applicable
Council of Europe Technical Guides, EU and member States’ legislation or
recommendations for food contact materials and articles.

3.1. Substances used in the manufacture of food contact materials and

articles
In the manufacture of food contact materials and articles, substances may
only be used after risk assessment has been performed according to the
principles stated hereafter under section 4; assessment includes considera-
tion of impurities, reaction and/or degradation products.
Substances can be used in the manufacture of food contact materials and
articles, in compliance with any restrictions applicable to them, if they
meet any of the following criteria:
a. they are approved by competent authorities of the Council of Europe
member States concerned, in accordance with the procedures for the
elaboration of lists of officially evaluated substances; or
b. their use is in compliance with material-specific provisions in EU or na-
tional legislation or official recommendations, as specified in the appli-
cable Technical Guide; or
c. absence of their release into food and absence of release into food of
their impurities, and known or foreseeable reaction or degradation
products can be demonstrated by a method of analysis in accordance
with Article 34 of Regulation (EU) No. 2017/625 or relevant national leg-
islation with a limit of detection not higher than 0.01 mg/kg. This limit
shall apply to groups of compounds if they are structurally and toxico-
logically related, in particular isomers or compounds with the same rel-
evant functional group.
In the case of substances, their impurities and known or foreseeable reac-
tion or degradation products that belong to any of the following categories

18
 Resolution CM/Res(2020)9

and meet criterion 3.1 c, demonstrating absence of release is not sufficient

and therefore a specific risk assessment must be performed:
• substances in nano-form;5
• substances classified as “mutagenic”, “carcinogenic” or “toxic to repro-
duction” in accordance with the criteria set out in sections 3.5, 3.6 and
3.7 of Annex I to Regulation (EC) No. 1272/2008 of the European Parlia-
ment and the Council of 16 December 2008 on classification, labelling
and packaging of substances and mixtures;
• substances which are assessed to be genotoxic or predicted to be geno-
toxic using (Q)SAR models if valid data (e.g. complying with the Euro-
pean Food Safety Authority’s (EFSA) criteria) confirming absence of
genotoxicity are not available.
Criterion 3.1 c applies without prejudice to applicable European and national
provisions or the provisions set out in the applicable Technical Guide.
d. When none of the criteria a, b and c are met and without prejudice to
applicable European and national provisions, or the provisions set out
in the applicable Technical Guide, substances may be used in the man-
ufacture of food contact materials and articles, if they are risk-assessed
in accordance with section 4 by or on behalf of the responsible
business operator and incompliance with Article 3 of Regulation (EC)
No. 1935/2004 or relevant national legislation.

3.2. European Committee for Food Contact Materials and Articles

(CD-P-MCA)6
The CD-P-MCA, in accordance with its terms of reference and resources
permitting, prepares technical guidance that supplements the Guiding
Principles of the resolution. Further to section 3.1 a, the Committee agrees
on the procedures for creating, publishing and updating lists of officially
evaluated substances.

5 Nanomaterials as defined in Commission Recommendation 2011/696/EU of

18 October 2011 on the definition of nanomaterials (OJ L 275, 20.10.2011, p. 38).
6 CD-P-MCA stands for Steering Committee – Partial Agreement – European Com-
mittee for Food Contact Materials and Articles (Comité directeur – Accord partiel
– Comité européen sur les matériaux et objets pour contact alimentaire).

19
Metals and alloys used in food contact materials and articles

When new substances are subject to assessment and/or authorisation for

use in the manufacture of food contact materials and articles, member
States are advised to share relevant information with the CD-P-MCA with
a view to updating any lists of evaluated substances as indicated in 3.1 a.

3.3. SML, SRL, OML, ORL, QM and QMA

1. Food contact materials and articles should not transfer their constituents
to foodstuffs or food simulants in quantities exceeding the limits set
out in the applicable Technical Guides (i.e. specific or overall release or
migration limits or restrictions for the material composition to limit the
amount of certain components referred to as “QM” and “QMA”).
2. Unless otherwise specified, a generic SML or SRL of 60 mg/kg applies
to those substances listed in the applicable Technical Guide for which
no specific release or migration limit or other restrictions are provided.

4. Risk Assessment
The safety of substances used in food contact materials and articles shall be
evaluated in accordance with internationally recognised scientific princi-
ples on risk assessment, and with, where appropriate, EFSA guidance.7 The
safety evaluations shall also take into account impurities and known or
foreseeable reaction and degradation products.
The risk assessment should be reviewed whenever relevant composition or
process changes are implemented or new scientific or other data become
available.

5. Labelling
Food contact materials and articles not yet in contact with food when
placed on the market shall be labelled in accordance with Article 15 of
Regulation (EC) No. 1935/2004 or relevant national legislation to ensure

7 Note for guidance for the preparation of an application for the safety assessment of
a substance to be used in plastic food contact materials:
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2008.21r;
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2379;
https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2017.5113.

20
 Resolution CM/Res(2020)9

safe and appropriate use. The label shall be sufficiently clear to avoid any
misuse or misinterpretation. It shall not mislead consumers and not rule
out reasonably foreseeable uses of repeated use articles.

6. Traceability
Traceability of food contact materials and articles shall be ensured at all
stages in accordance with Articles 15 and 17 of Regulation (EC) No. 1935/2004
or relevant national legislation.

7. Good Manufacturing Practice

Food contact materials and articles shall be manufactured in accordance
with Regulation (EC) No. 2023/2006 on good manufacturing practice for
materials and articles intended to come into contact with food, or with rel-
evant national legislation. If appropriate, guidelines on good manufactur-
ing practice developed by trade and producer associations can also be taken
into account without prejudice to any applicable member State legislation.

8. Compliance Documents

8.1. Documents supporting compliance and safety (supporting

documentation)
Appropriate documentation, demonstrating that food contact materials
and articles under the scope of the resolution comply with the requirements
applicable to them, must be available from each business operator along the
supply chain. It should be compiled as “supporting documentation” and
provided to the competent authorities on request, without undue delay.
The supporting documentation is a record, especially of:
• the substance(s) used and corresponding risk assessment (including
reference to relevant legislation or recommendation), the process(es)
applied, and the reaction(s) and treatment(s) performed;
• the safety of released substances, including impurities and reaction and
degradation products, and evidence for compliance with the applicable

21
Metals and alloys used in food contact materials and articles

requirements supported with data or other adequate reasoning, taking

into account the level of release or migration under the most severe con-
ditions of use;
• if applicable, the conditions and results of migration/release testing, i.e.
the description of the applied methods and other relevant information,
calculations (including modelling), toxicological test descriptions and
data as well as the reasoning used for the conclusion.
The supporting documentation may be confidential; however, protection
of information in the documentation must not compromise the safety of
food contact materials and articles and must not prevent a business oper-
ator from disclosing safety information related to released substances and
conditions of use in the declaration of compliance.

8.2. Declaration of compliance

Food contact materials and articles under the scope of the resolution are to
be accompanied by a declaration of compliance.
The declaration of compliance means that the manufacturer of the food
contact material or article assumes responsibility for the suitability for food
contact, including the safety of all released substances or, whenever appli-
cable, explicitly informs the next business operator in the supply chain
of the compliance work that needs to be completed. The declaration also
specifies the limitations to the applications of the food contact material or
article, any further processing and treatments as well as conditions of food
contact and is based on the documentation referred to under 8.1.
The declaration of compliance provides all relevant information to enable
subsequent business operators along the supply chain to carry out any
additional compliance work in order to deliver safe and compliant food
contact materials and articles.
A declaration of compliance is issued at all stages of the supply chain. It is
available at all marketing stages, other than the retail stage, and includes,
at least (if applicable):
a. the identity and address of the business operator issuing the declaration
of compliance;
b. the date the declaration was issued;

22
 Resolution CM/Res(2020)9

c. the identity and address of the manufacturer or importer of the food

contact material/article;
d. the identity of the food contact material/article (final or intermediate)
or substance intended for the manufacture of the said material/articles
(chemical name or description and trade name);
e. confirmation that the food contact material or article (final or inter-
mediate) or substance intended for the manufacture of any material or
article complies with the applicable legal or other relevant provisions
and requirements laid down in the Guiding Principles and in the appli-
cable Technical Guide;
f. specifications and conditions ensuring safe use of the food contact ma-
terial/article (e.g. types of foods for which it can be used, maximum
temperature, duration of contact, repeated or single contact, the highest
food contact surface area to volume ratio for which compliance has been
verified);
g. whenever applicable, a statement that the substances used are specified:
i. in the corresponding Council of Europe list of officially evaluated
substances; or
ii. in European or national legislation or official recommendations as
referenced in the applicable Technical Guide, providing the exact ref-
erence;
h. whenever applicable, a statement that:
i. risk assessment has been performed by or on behalf of the business
operator for substances that are detailed in the supporting documen-
tation;
ii. the use of these substances does not infringe relevant EU or national
legislation or official recommendations;
iii. the use of these substances is not in conflict with the provisions set
out in the applicable Technical Guide;
i. adequate information on the substances used, impurities and reaction
and degradation products for which restrictions and/or specifications
apply;
j. adequate information on the substances which are subject to a restric-
tion regarding their use in food (dual use additives);

23
Metals and alloys used in food contact materials and articles

k. information on substances used, impurities and reaction and degrada-

tion products, including those known or foreseen to be generated at later
production stages, for which the business operator has identified that
further compliance work needs to be conducted at the next stages in the
supply chain.
If necessary, additional requirements or derogations for particular types of
food contact materials/articles may be specified in the applicable Technical
Guides.
The declaration is renewed whenever substantial changes are made to the
composition or to the production process that may affect the compliance
of materials/articles, or in response to relevant scientific or regulatory
developments.

9. Compliance Testing
Compliance of the food contact materials and articles with the relevant pro-
visions and restrictions shall be verified by appropriate scientific methods
(including modelling or worst case calculations) in accordance with Regu-
lation (EU) No. 2017/625 or relevant national legislation.
Tests on release from the material or article into foodstuffs are carried out
under the reasonable worst-case conditions during manufacture, storage,
distribution and normal or foreseeable use, with respect to time, tempera-
ture and composition of the foodstuff.
When it is not feasible or not practical to test release into foodstuffs, food
simulants are used to imitate the respective foodstuffs. The food simulants
and conditions of contact are selected in such a way that release is at least
as high as into food. Specifications for the choice of simulants and test con-
ditions may be laid down in the relevant Guidelines of the Joint Research
Centre (JRC) of the European Commission and the applicable Technical
Guides.
For verification of compliance with the SML or SRL, solely release from
food contact materials and articles (not contamination from any other
sources) is taken into account.

24
 Resolution CM/Res(2020)9

10. Technical Guides

The Technical Guides supplementing the resolution8 cover specific and
detailed material requirements and principles as regards the safety and
quality of food contact materials and articles.
Technical Guides may cover the following areas:
• general provisions (especially purpose/scope, additional definitions);
• specific requirements (or derogations from general principles) related to
the particular material, including particular labelling requirements, if
applicable;
• if applicable, officially evaluated substances used for the manufacture of
the particular type of food contact material or article including relevant
restrictions and specifications applicable to them;
• if applicable, material-specific provisions in European or national legis-
lation or official recommendations;
• testing conditions and methods of analysis;
• additional information relating to supporting documentation and dec-
laration of compliance, if applicable.
Technical Guides are published under the aegis of the EDQM and will be
regularly updated, as necessary, by the CD-P-MCA.

8 Technical Guides are available on the EDQM Website.

25
Abbreviations used in this Technical Guide

ADI Acceptable Daily Intake

AI Adequate Intake
ANSES (formerly AFSSA) Agence nationale de sécurité
sanitaire de l’alimentation, de l’environnement et du
travail (French Agency for Food, Environmental and
Occupational Health & Safety)
ALARA As Low As Reasonably Achievable
ATSDR Agency for Toxic Substances and Disease Registry
BfR Bundesinstitut für Risikobewertung (German Federal
Institute for Risk Assessment)
BMD Benchmark dose
BMDL Benchmark dose lower confidence limit
BW Body Weight
CD-P-MCA European Committee for Food Contact Materials and
Articles
CEN Comité européen de normalisation (European Committee
for Standardization)
CONTAM Panel on Contaminants in the Food Chain (EFSA)
COT Committee on Toxicity of Chemicals in Food, Consumer
Products and the Environment (UK)
EC European Commission
EFSA European Food Safety Authority

27
Metals and alloys used in food contact materials and articles

EPA Environmental Protection Agency (USA)

EVM Expert Group on Vitamins and Minerals (UK)
FAO United Nations Food and Agriculture Organisation
FCM Food Contact Material(s)
FSA Food Standards Agency (UK)
FSS Food Standards Scotland (UK)
GMP Good Manufacturing Practice
ICH International Council for Harmonisation of Technical
Requirements for Pharmaceuticals for Human Use
IPCS International Programme on Chemical Safety
ISO International Organization for Standardization
JECFA Joint FAO/WHO Expert Committee on Food Additives
JRC Joint Research Centre (EC)
LB Lower Bound
LOAEL Lowest Observed Adverse Effect Level
LOD Limit of Detection
LOQ Limit of Quantification
MOE Margin of Exposure
NDA Scientific Panel on Dietetic Products, Nutrition and
Allergies (EFSA)
NOAEL No Observed Adverse Effect Level
PDE Permitted Daily Exposure (as used in the ICH Guideline
on elemental impurities, ICH Q3D(R1))
P(M)TDI Provisional (Maximum) Tolerable Daily Intake
PTMI Provisional Tolerable Monthly Intake
PTWI Provisional Tolerable Weekly Intake
RASFF Rapid Alert System for Food and Feed

28
 Abbreviations

REACH Registration, Evaluation, Authorisation and Restriction of

Chemicals
RfD Reference Dose (established by EPA – maximum
acceptable oral dose of a toxic substance derived from the
NOAEL)
RIVM Rijksinstituut voor Volksgezondheid en Milieu (Dutch
National Institute for Public Health and the Environment)
SCF EU Scientific Committee on Food
SR Specific Release
SRL Specific Release Limit
SML Specific Migration Limit
TDI Tolerable Daily Intake
TRV Toxicological Reference Value
TWI Tolerable Weekly Intake
UB Upper Bound
WHO World Health Organization

29
Chapter 1 – General provisions and
specific release limits for metals

Introduction
Metals and alloys are used in FCM and articles in food processing equip-
ment, containers and household utensils as well as in foil used to wrap food.
These materials are frequently used as a safety barrier between the food
and the environment. They are often covered with a coating to reduce ion
release into foods.
Metal ions can be released from materials into food and may endanger the
health of the consumer if the intake exceeds the TRV, or may unacceptably
alter the composition of the food or its organoleptic characteristics. Conse-
quently, it was decided to establish technical guidance in this area.

Objectives
This Technical Guide on Metals and alloys used in food contact materi-
als and articles supplements the guiding principles stated in Resolution
CM/Res(2020)9. It is not legally binding and is intended to assist national
regulators when preparing or updating legal provisions on FCM made from
metals and alloys, with a view to harmonising regulations and enforcement
activities at the European level.
Safety reviews of individual metals and the restrictions defined for metals
and alloys used in FCM and articles are updated regularly to keep up with
scientific and technical progress.
Practical recommendations for release testing and checking compliance
with the applicable restrictions provide support to manufacturers, import-
ers and control laboratories.

31
Metals and alloys used in food contact materials and articles

Involvement of national experts and stakeholders

Governments of Council of Europe member states1 participated actively
in the elaboration of Resolution CM/Res(2020)9 and the updating of the
Technical Guide. Their representatives in the European Committee for
Food Contact Materials and Articles (CD-P-MCA) are experts in the area
of FCM or are responsible for the implementation of government policies
in their national ministries.
Whereas Resolution CM/Res(2020)9 was approved by the Council of
Europe’s Committee of Ministers, this Technical Guide has not been sub-
mitted for approval in view of its technical nature and the need for timely
updates.
The European Commission (EC), the EC’s Joint Research Centre (JRC) and
EFSA participate in the ongoing work of the CD-P-MCA.
Experts from national authorities, the JRC, industry, private testing labora-
tories and other stakeholders continue to share their knowledge and exper-
tise and to contribute to the updating of this Technical Guide.
The draft revised Technical Guide was subject to further consultations with
relevant professional associations and industry representatives.

Legal status of the Technical Guide and link with

the European Union
Council of Europe technical guides are not legally binding for member
states, but serve as a reference for the implementation of Article 3 of Regu-
lation (EC) No 1935/2004, where applicable. The member states may include
reference to these guides in national provisions or transpose the text into
national law. It is important for business operators to refer to the national
law in the market onto which they intend to place the item.

1 Albania, Austria, Belgium, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus,

Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland,
Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Montenegro, Netherlands,
North Macedonia, Norway, Poland, Portugal, Republic of Moldova, Romania,
Serbia, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Türkiye, Ukraine
and United Kingdom.

32
 GENERAL PROVISIONS AND SRLs FOR METALS

Definitions, scope and specific release limits

1. Definitions
The definitions of the resolution apply in the context of this Technical Guide.
In addition, the following definitions apply:

1.1 Metals
Metals are characterised by their chemical and physical properties in the
solid state:
• reflectivity, which is responsible for the characteristic metallic lustre;
• electrical conductivity, which decreases with increasing temperature;
• thermal conductivity;
• mechanical properties, such as strength and ductility.
Metals are the class of materials linked, on an atomic scale, by metallic
bonds. They can be considered an array of positive metallic ions forming
long-range crystal lattices in which valency electrons are commonly shared
throughout the structure.

1.2 Alloys
An alloy is a metallic material composed of two or more elements. Alloys
are homogeneous at a macroscopic scale and their components cannot be
separated by mechanical means.

1.3 Release
Release is defined herein as the unintentional transfer to food of metal ions
from FCM and articles made of metal or alloy.

2. Scope

2.1 Included in the scope

The provisions laid down in this chapter apply to the unintentional release
of certain metal ions from materials and articles at the end-use level, made

33
Metals and alloys used in food contact materials and articles

completely or partially of metals and alloys, coated* or uncoated, manufac-

tured or imported into Europe, which in their finished state:
a. are intended to be brought into contact with food; or
b. are already in contact with food and were intended for that purpose; or
c. can reasonably be expected to be brought into contact with food or to
transfer their constituents to food under normal or foreseeable condi-
tions of use.
*Note: For metals and alloys used in FCM and articles that are
covered with an organic surface coating that has been demon-
strated to restrict release of metal ions to less than the applicable
SRL, routine testing for compliance with this Technical Guide may
be omitted.
Examples: household utensils, kitchen appliances and industrial processing
equipment such as food processors, wrapping, containers, pots, blenders,
knives, forks, spoons, etc.

2.2. Excluded from the scope

These provisions do not apply to:
a. materials and articles which are supplied as antiques;
b. ceramics, enamels, crystal glass, printing inks, polymerisation aids and
other types of FCM that are either covered by specific legislation in the
EU or at national level or by Council of Europe resolutions;
c. FCM that were designed to release certain substances into the food
(so-called ‘active FCM’); such materials have been addressed in EU leg-
islation on active FCM [Regulation (EC) No 1935/2004 and Regulation
(EC) No 450/2009];
d. fixed public or private water supply equipment.
Contribution to the total intake of metal ions due to sources of exposure
other than metals and alloys used in FCM and articles has been taken into
consideration by applying allocation factors, where appropriate, when
deriving SRLs.

34
 GENERAL PROVISIONS AND SRLs FOR METALS

3. Labelling
In addition to the requirements in Article 5 of Resolution CM/Res(2020)9,
manufacturers of metallic FCM and articles should provide information
on the composition, as applicable (e.g. when the content of impurities has
been restricted), and their use to reduce the risk of unintentional release.
Cleaning methods, temperature and storage time are known to influence
the release of metal ions from metals and alloys used in FCM and articles
into certain types of foodstuff. Thus, labelling could be used to highlight
restrictions for the storage and processing of strongly acidic, alkaline or
salted foodstuffs to minimise the phenomenon of corrosion. The labelling
could also include guidance on selecting cleaning and disinfection regimes
to ensure that the integrity of the FCM and/or the organoleptic properties
of the food are not compromised, and on the storage temperature of foods
in order to minimise release. However, producers shall take the foreseea-
ble use by consumers into account and therefore they should consult the
latest version of the guidelines on Testing conditions for kitchenware arti-
cles in contact with foodstuffs: Plastics, Metals, Silicone & Rubber (Beldi et
al., 2021).
The labelling could, for example, state:
• ‘User information: do not use this equipment with acidic or alkaline
or salted foodstuffs’; or
• ‘Exclusively for use with non-acidic foodstuffs stored in refrigerators’;
or
• ‘Keep below 5°C if the food is to be stored for longer than 24 hours’.
If users must initially wash the material, then the labelling should provide
appropriate cleaning and care instructions.
Remarks: It should be recognised that industrial use and household use of
FCM may vary extensively.
An industrial environment usually implies:
• in-process controls;
• repeated use of the same equipment according to standard conditions;
• selection and qualification of the FCM (equipment or packaging) for a
given range of foodstuffs and its use;

35
Metals and alloys used in food contact materials and articles

• possible liability of the manufacturer in case of harm to consumers.

Household use usually implies:
• a wide range of foodstuffs and contact conditions;
• uncontrolled use of utensils limited only by concepts such as current
practice or reasonably foreseeable use conditions.

4. Specific release limits

FCM and articles within the scope of this Technical Guide comply with
the SRLs set out below in Tables 1 and 2. SRLs are expressed in mg/kg food.

Table 1. SRLs for metals and alloy components

Symbol Name SRL [mg/kg food]

Al Aluminium 5
Sb Antimony 0.04
Cr Chromium (III) 1*
Co Cobalt 0.02
Cu Copper 4
Fe Iron 40
Mg Magnesium –§
Mn Manganese 0.55
Mo Molybdenum 0.12
Ni Nickel 0.14
Ag Silver 0.08†
Sn Tin 100‡
Ti Titanium –§
V Vanadium 0.01
Zn Zinc 5
Zr Zirconium 2
* For chromium (VI), see Chromium (Cr) in Chapter 2.
†
See See Chapter 3, Annex II for information on applying a reduction factor when assessing
the compliance of cutlery made from silver and silver-plated cutlery.
‡
Except in the field of application under Commission Regulation (EU) 2023/915.
§
The generic SRL of 60 mg/kg food is not applicable.

36
 GENERAL PROVISIONS AND SRLs FOR METALS

Table 2. SRLs for metals as contaminants and impurities

Symbol Name SRL [mg/kg food]

As Arsenic 0.002
Ba Barium 1.2
Be Beryllium 0.01
Cd Cadmium 0.005
Pb Lead 0.010
Li Lithium 0.048
Hg Mercury 0.003
Tl Thallium 0.001

Establishing an SRL
Toxicological information, the ALARA principle, where appropriate, and
relevant legislation are considered. Each metal ion requires a specific
approach for setting an SRL, avoiding either over-conservative SRLs or mea-
ningless and unachievable limits.
The following criteria are also considered when defining an SRL:
• appropriate TRVs (e.g. JECFA, EFSA or national risk assessment
bodies);
• appropriate exposure assessments, based on oral intake data from
food, drinking water and other sources from several European
countries;
• allowances for FCM as one possible source for the human exposure
(next to food and dietary supplements): expressed as percentage of
the TRV;
• actual release data: rather than setting an SRL on the basis of TRVs,
actual release data may serve to define technically lowest feasible
levels (ALARA) and levels usually achieved with GMP;
• any regulations governing the presence of metal ions in foodstuffs
are taken into consideration to avoid conflicts between standards.
Based on the above criteria, the following model approach was used to set
SRLs for metals used in FCM:

37
Metals and alloys used in food contact materials and articles

Criterion 1: appropriate TRVs exist and oral intake data of sufficient quality are
available.
Calculation of the SRL:
(i) For oral intake data of sufficient quality not exceeding the toxicological
limit: based on the TRV and a variable, justified allowance in the case of a
gap between worst-case oral intake (95th percentile) and the TRV.
Examples in this Technical Guide: Cu, Mo and Zn.
(ii) For oral intake data of sufficient quality exceeding the toxicological
limit: based on the ALARA principle.
Example in this Technical Guide: Al.

Criterion 2: appropriate TRVs exist, but insufficient or no oral intake data are
available.
Calculation of the SRL: based on the TRV and a fixed allowance of 20%,
which is in agreement with the WHO Guidelines for Drinking-water
Quality (WHO, 2022).
Examples in this Technical Guide: Co and Ni.

Criterion 3: appropriate TRVs do not exist, but oral intake data are available.
Calculation of the SRL:
(i) Based solely on appropriate oral intake data; as no toxicologically derived
limit exists, no allowance can be applied.
Examples in this Technical Guide: Ag and V.
(ii) For varying oral intake data; as no toxicologically derived limit exists,
based on the ALARA principle.
Example in this Technical Guide: Fe.

Criterion 4: Metals without an SRL.

Setting an SRL for Mg and Ti was not considered necessary.

38
 GENERAL PROVISIONS AND SRLs FOR METALS

Criterion 5: metals and metalloids considered as impurities.

Calculation of the SRL: based on a fixed allowance of 10% of the TRV, which
is applied independently of oral intake data with the exception of Cd (25%
allowance) and Pb (26% allowance).
Examples in this Technical Guide: As, Ba, Be, Cd, Hg, Li, Pb and Tl.

Criterion 6: appropriate TRVs exist, but actual release data show much lower
release when using GMP.
In order to ensure the use of GMP a lower release limit was chosen.
Example in this Technical Guide: Cr.

Updating of this Technical Guide and further

provisions or guidance
When updating this Technical Guide the technical specifications for metals
and alloys defined in International (ISO) and European standards (CEN)
are also taken into account, as well as national legislation on the composi-
tion of metals and alloys.

References
Beldi G, Senaldi C, Robouch P, et al. Testing conditions for kitchenware articles in contact
with foodstuffs: Plastics, Metals, Silicone and Rubber. EC JRC, JRC125894; 2021.
EC. Commission Regulation (EU) 2023/915 of 25 April 2023 on maximum levels for certain
contaminants in food and repealing Regulation (EC) No 1881/2006. Official Journal of the
European Union 2023;L 119/103.
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

39
Chapter 2 – Safety review and
recommendations

Metals and alloy components

The following metals are relevant metals and alloy components used in
FCM and articles.
Aluminium (Al)
Antimony (Sb)
Chromium (Cr)
Cobalt (Co)
Copper (Cu)
Iron (Fe)
Magnesium (Mg)
Manganese (Mn)
Molybdenum (Mo)
Nickel (Ni)
Silver (Ag)
Tin (Sn)
Titanium (Ti)
Vanadium (V)
Zinc (Zn)
Zirconium (Zr)

41
 Al
Aluminium (Al)

Aluminium is the third most abundant element

in the Earth’s crust and is widespread in minerals.
It does not occur in nature in a free element state
because of its reactive nature (Beliles, 1994). Many of
its naturally occurring compounds are insoluble at
neutral pH and thus concentrations of the element
in both fresh and sea water are usually low, less
than 0.1 mg/L. Inorganic compounds of aluminium
normally contain Al(III). Pure aluminium has good
working and forming properties and high ductility,
its mechanical strength being low. Aluminium
is often used in alloys with copper, magnesium,
manganese, and zinc (Yokel and Sjögren, 2022).

Sources and levels of intake

The main source of aluminium is the naturally occurring content in food-
stuffs. Mean aluminium content in unprocessed foodstuffs ranges from
around or less than 1 mg/kg in eggs, fats and oils, fruits, vegetables and
juices to around 5 mg/kg in tea (AGES, 2017; EFSA, 2008; Kolbaum et al.,
2019; Tietz et al., 2019). Exceptionally high aluminium content has been
found in spices, mussels, nuts, legumes and oilseeds (around 30-244 mg/kg,
with the highest content in spices, Tietz et al., 2019). Due to processing or
the use of aluminium-containing food additives, the aluminium content of
processed foodstuffs can be higher than for the respective raw products (e.g.
for bitter chocolate, sugar, confectionary, coffee, cocoa and tea infusions
(Kolbaum et al., 2019; Tietz et al., 2019). It should be noted that in the EU,
the use of aluminium and its salts as a food additive is restricted by Reg-
ulation (EC) No 1333/2008, as amended, to a limited number of foodstuffs.

43
Al
Metals and alloys used in food contact materials and articles

Mean dietary exposure from water and food in non-occupational exposed

adults showed large variations between different countries and, within
a country, between different surveys. In studies from the late 1990s and
early 2000s, as summarised in EFSA (2008), it ranged from 0.2 to 1.5 mg/kg
bw/week. In children, estimated exposure at the 97.5th percentile ranged
from 0.7 to 1.7 mg/kg bw/week. In recent studies, the estimated weekly
intake was lower: ANSES (2011) estimated a weekly aluminium intake for
adults from food of 0.28-0.49 mg/kg bw/week (mean – 95th percentile), and
for children (3-14 years) of 0.44-0.83 mg/kg bw/week. In 2016, ANSES esti-
mated a weekly intake for infants (0-3 years) from food of 0.21-0.62 mg/kg
bw/week (mean – 90th percentile). The estimated exposure of Austrian
infants (0-6 months) fed with infant formula was in the same range
(AGES, 2017). Kolbaum et al. (2019) and Tietz et al. (2019) estimated the
weekly aluminium intake of German adults from food as 0.18-0.44 mg/kg
bw/week (mean – 95th percentile). Food groups with the highest impact
on overall aluminium uptake were instant tea and tea beverages, vegeta-
bles and salads, bitter chocolate, cereals and cereal products like bread and
rolls (ANSES, 2011; Kolbaum et al., 2019; Tietz et al., 2019). However, the
main food groups accounted for only around one third of the overall alu-
minium intake. Contributors to the remaining two thirds of the overall
intake are diversely distributed among food groups and cannot be assigned
to a specific consumption pattern (Kolbaum et al., 2019; Tietz et al., 2019).
The Istituto Superiore di Sanità (ISS) estimated the aluminium exposure of
Italian consumers from the use of aluminium FCM to be in the range of
0.06-0.68 mg/kg bw/week for children and adolescents and in the range of
0.07-0.39 mg/kg bw/day for adults (Feliciani et al., 2019).
Significant non-dietary sources of exposure to aluminium can be medi-
cines (e.g. antacids or buffered aspirins) (Krewski et al., 2007) and cosmet-
ics via oral and dermal routes (e.g. antiperspirants) (AFSSAPS, 2011; Tietz
et al., 2019). However, recent studies showed that the dermal uptake of alu-
minium and its salts may be significantly lower than estimated in earlier
studies (SCCS, 2020).

44
 Al
Aluminium (Al)

Metallic food contact materials

Aluminium is widely used in food preparation and storage such as in cook-
ware, coffee pots, beverage cans (Yokel and Sjögren, 2022) and in packaging
such as food trays. Aluminium FCM are often coated with a resin-based
coating. Aluminium alloys for FCM may contain alloying elements such as
magnesium, silicon, iron, manganese, copper and zinc (European Standard
EN 601; European Standard EN 602).

Other food contact materials

Aluminium can be found in glass containers and plastic FCM (Yokel and
Sjögren, 2022).

Release
Aluminium and its various alloys are highly resistant to corrosion (Beliles,
1994). When exposed to air, the metal almost immediately develops a thin
film of Al2O3. The reaction then slows because this film seals off oxygen,
preventing further oxidation or chemical reaction. The film is colourless,
tough and non-flaking. Few chemicals can dissolve it (Beliles, 1994).
Aluminium reacts with acids. Pure aluminium is attacked by most dilute
mineral acids. At neutral pH, aluminium hydroxide has limited solubil-
ity. Alkalis rapidly attack both pure and impure aluminium and dissolve
the metal (Hughes, 1992). Therefore, aluminium can be released from
uncoated surfaces in contact with foodstuffs. Furthermore, aluminium
can be released from coated FCM if the coating does not act as a functional
barrier. Release of aluminium from FCM depends to a large extent on the
pH of the foodstuffs. High salt concentrations (over 3.5% NaCl) can also
increase ion release. Use of aluminium saucepans and aluminium-lined
cooking utensils and containers may increase the content of aluminium
in certain types of foodstuffs, especially during long-term storage of
strongly acidic, alkaline or salty foodstuffs. In general, cooking in alumin-
ium vessels increased the content in the foodstuffs by less than 1 mg/kg
for about half of foodstuffs, and less than 10 mg/kg for 85% of the food-
stuffs examined by Pennington and Jones (1989). Boiling tap water in an

45
Al
Metals and alloys used in food contact materials and articles

aluminium pan for 10 or 15 minutes can result in aluminium release of up

to 1.5 mg/L, depending on the acidity of the water and the chemical compo-
sition of the aluminium utensils (Gramiccioni et al., 1996; Mei et al., 1993;
Müller et al., 1993; Nagy et al., 1994) but values up to 5 mg/L were reported
in one study (Liukkonen-Lilja and Piepponen, 1992). Acidic foodstuffs such
as tomatoes, cabbage, rhubarb and many soft fruits most frequently take
up more aluminium from containers (Hughes, 1992). While acids give the
highest figures, alkaline foodstuffs (less common) and foodstuffs with
much added salt also increase aluminium uptake (Gramiccioni et al., 1996;
Hughes, 1992).
Temperature and storage time are known to influence the release of alu-
minium into foodstuffs. In a release study using 3% acetic acid, the release
was approximately 10-fold higher at 40°C compared to 5°C after 24 hours
(Gramiccioni et al., 1987). Typical values for release of aluminium from foil
was < 0.05 mg/dm2 at 5°C and 6 mg/dm2 at 40°C. However, after 10 days, the
release was considerably higher: 0.5 mg/dm2 at 5°C compared to 96 mg/dm2
at 40°C (Gramiccioni et al., 1987). Baking different types of meat wrapped
in aluminium foil showed an increased aluminium release compared to
raw meat up to 5-fold depending on the temperature (up to 17.2 mg Al/kg
wet weight) (Turhan, 2006).
Combined effects of high temperatures during baking or grilling and
salt/low pH (addition of vinegar) on aluminium release were demonstrated
by baking fish in aluminium foil. Baking the fish without any addition of
salt and vinegar led to increased aluminium content up to 4-fold (up to
0.4 mg Al/kg wet weight) compared to the raw fish. When salt and vinegar
were added, the aluminium content was increased up to 68-fold (up to 5 mg
Al/kg wet weight) (Ranau et al., 2001).
Sander et al. (2018) showed aluminium release of up to 20 mg/kg from
uncoated aluminium menu trays into sauerkraut juice, tomato puree and
applesauce during the cook and chill process. In a similar study, using
a wide range of commercially prepared foods that are typically served
(stored and heated) in aluminium trays, Nehring (2018) showed that the
release of Al can be kept below 5 mg/kg in most foods, with the exception
of aggressive ones (sausage salad with a vinegar-based brine, tomato sauce
and tomato soup). For the same food, the study showed large deviations

46
 Al
Aluminium (Al)

between different aluminium trays that could be attributed either to the

quality of aluminium or to the applied contact surface to volume ratio.

Safety aspects
• In 1988, JECFA established a PTWI of 7 mg/kg bw/week for total alumin-
ium intake, including food additive uses of aluminium salts, which was
subsequently lowered to 1 mg/kg bw/week in 2006 (JECFA, 1989, 2006).
In light of new data, JECFA reassessed aluminium in 2011 and introduced
a new PTWI of 2 mg/kg bw/week based on a NOAEL of 30 mg/kg bw/day
and an uncertainty factor of 100 (JECFA, 2012).
• The Scientific Committee on Consumer Safety (SCCS) agreed on the
NOAEL of 30 mg/kg bw/day used by JECFA for risk assessment (SCCS,
2020).
• In 2017, the Scientific Committee on Health, Environmental and Emerg-
ing Risks (SCHEER, 2017) published an opinion on tolerable intake of
aluminium with regard to adapting the migration limits for aluminium
in toys. SCHEER established a TDI of 0.3 mg/kg bw based on the same
NOAEL of 30 mg/kg bw per day.
• WHO (2022) states that a ‘health-based value of 0.9 mg/L could be
derived from the JECFA PTWI (2006), but this value exceeds practicable
levels based on optimisation of the coagulation process in drinking-water
plants using aluminium-based coagulants’.
• Directive (EU) 2020/2184 on the quality of water intended for human
consumption gives a standard value of 0.2 mg/L for water for human
consumption as a compromise between the practical use of aluminium
salts in drinking water treatment and discolouration of distributed water.
• Only a small amount of ingested aluminium is absorbed (mean 0.1%
according to EFSA, 2008). After absorption, aluminium is mainly (80-
90%) excreted via urine (Priest, 1995). Unexcreted aluminium is dis-
tributed into all tissues, and accumulation takes place especially in the
bones, muscles, kidneys and brain (COT, 2013; EFSA, 2008; JECFA, 2012).
However, soluble aluminium salts are more easily absorbed. Patients
with impaired renal function treated by dialysis could show a higher

47
Al
Metals and alloys used in food contact materials and articles

aluminium blood level. In the past, some of these dialysis patients have
shown neurological symptoms of aluminium intoxication due to an
inappropriate treatment that is no longer used; these symptoms were
sometimes mistaken for those of Alzheimer’s disease. WHO (IPCS, 1997)
concluded that a causal relationship between aluminium intake and
Alzheimer’s disease could not be inferred from these studies.
• In 2008, EFSA confirmed the PTWI of 1 mg/kg bw/week previously
established by JECFA in 2006. In 2018, EFSA reviewed new toxicologi-
cal evidence but not with the aim of revising the health-based guidance
value for aluminium set by EFSA in 2008.

Conclusions and recommendations

the SRL for aluminium of 5 mg/kg food or food
simulant is reasonably achievable

In the case of aluminium, exposure of certain groups of the population is

close to or exceeds the PTWI derived by JECFA (2012) of 2 mg/kg bw/week
(Tietz et al., 2019) and the TDI of 0.3 mg/kg bw/day accepted by SCHEER
(2017). Certain FCM and articles contribute to the dietary intake of alumin-
ium. Therefore, it is recommended that the SRL for aluminium be set at
ALARA level. Such an approach ensures that the manufacturer will apply
measures to prevent and reduce the release of aluminium from FCM and
articles as far as possible in order to protect public health.
Data provided by industry and member states show that the SRL of 5 mg/kg
is reasonably achievable at present.
This SRL should be subject to regular review to take account of the advance
of scientific and technical knowledge and improvements in GMP.
Based on the current state of the art and available release data from uncoated
aluminium FCM (Feliciani et al., 2019), such food contact articles can be
safely used in various applications. It is nevertheless considered necessary
to limit the categories of food that may be in contact with uncoated alu-
minium articles and to introduce adequate labelling for users (Regulation
(EC) No 1935/2004, Article 15 1(b)).

48
 Al
Aluminium (Al)

It should be noted that FCM and articles made from aluminium coming
into contact with food must comply with the following additional
recommendations:
• Contact with acidic (e.g. fruit juices), alkaline (e.g. lye dough products) or
salty, liquid foodstuffs in uncoated aluminium utensils should be limited
in order to minimise release.
• The producer of the FCM should provide specific labelling for users of alu-
minium materials or articles not coated with a protective coating. With
regard to retail packs, the suppliers must ensure that these are labelled
with appropriate information for the end consumer. The labelling should
include the icon shown below (or equivalent)1

and the following statement: DO NOT USE WITH: ACIDIC FOOD (e.g.
peeled fruit, tomatoes, pickles, salad dressing) – SALTY FOOD (e.g. pret-
zels, white herring, cured meats).

References
Agence française de sécurité sanitaire des produits de santé (AFSSAPS). Évaluation du
risque lié à l’utilisation de l’aluminium dans les produits cosmétiques [Assessment of
the risks of using aluminium in cosmetic products]. October 2011 [available at https://
archive.ansm.sante.fr/content/download/36959/484513/version/3/file/Rapport-evaluation-
aluminium-Cosmetiques-2011.pdf, Summary in English: https://archive.ansm.sante.
fr/S-informer/Points-d-information-Points-d-information/Evaluation-du-risque-lie-
a-l-utilisation-de-l-aluminium-dans-les-produits-cosmetiques-Point-d-information,
accessed 21 February 2023].
Österreichische Agentur für Gesundheit und Ernährungssicherheit GmbH (AGES). Alu-
minium in Lebensmitteln und anderen verbrauchernahen Produkten [Aluminium in
food and other consumer products]. September 2017 [available at https://www.ages.at/

1 The icon shown was developed by the European Aluminium Foil Industry and can
be downloaded from the website www.label.alufoil.org.

49
Al
Metals and alloys used in food contact materials and articles

download/0/0/f36527a3b4b7b3060950f1f0378cd14410daa93a/fileadmin/AGES2015/Wissen-
Aktuell/Themenberichte/Aluminium_Wissen_aktuell.pdf, accessed 17 Nov 2022].
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 17 Nov 2022].
ANSES. Étude de l’alimentation totale infantile – Tome 2 – Partie 2 Composés inor-
ganiques [Infant Total Diet Study (iTDS) – Volume 2 – Part 2 Inorganic compounds].
September 2016 [available at https://www.anses.fr/en/content/infant-total-diet-study-itds,
accessed 20 Sep 2021].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th edition, Vol. II, Part C. New York: John Wiley & Sons, Inc.; 1994.
COT. Statement on the potential risks from aluminium in the infant diet. June 2013
[available at https://cot.food.gov.uk/sites/default/files/cot/statealuminium.pdf, accessed
17 Nov 2022].
CEN. Aluminium and aluminium alloys – Castings – Chemical composition of castings
for use in contact with foodstuff. Ref: EN 601:2004.
CEN. Aluminium and aluminium alloys – Wrought products – Chemical composition of
semi-finished products used for the fabrication of articles for use in contact with foodstuff.
Ref: EN 602:2004.
EFSA. Safety of aluminium from dietary intake – Scientific Opinion of the Panel on Food
Additives, Flavourings, Processing Aids and Food Contact Materials (AFC). EFSA Journal
2008;6(7):754. https://doi.org/10.2903/j.efsa.2008.754.
EFSA. Re-evaluation of aluminium sulfates (E 520–523) and sodium aluminium phosphate
(E 541) as food additives. EFSA Panel on Food Additives and Nutrient Sources added to
Food (ANS). EFSA Journal 2018;16(7):5372. https://doi.org/10.2903/j.efsa.2018.5372.
Yokel RA, Sjögren B. Aluminium. In: Nordberg GF, Costa M, editors. Handbook on the
toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
2022.
European Parliament. Directive (EU) 2020/2184 of the European Parliament and of the
Council of 16 December 2020 on the quality of water intended for human consumption.
Official Journal of the European Union 2020;63:1-62.
European Parliament. Regulation (EC) No 1333/2008 of the European Parliament and of
the Council of 16 December 2008 on food additives. Official Journal of the European Union
2008;51:16-33.
Feliciani R, Giamberardini S, Gesumundo C, et al. Studio dell’esposizione del consuma-
tore all’alluminio derivante dal contatto alimentare [Consumer exposure to aluminium in
contact with foods]. Rapporti ISTISAN 19/23 Istituto Superiore di Sanità. Available at https://
www.iss.it/rapporti-istisan/-/asset_publisher/Ga8fOpve0fNN/content/19-23-rev-studio-
dell-esposizione-del-consumatore-all-alluminio-derivante-dal-contatto-alimentare.
roberta-feliciani-silvia-giamberardini-cinzia-gesumundo-emanuela-testai-cinzia-le-

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Aluminium (Al)

donne-raffaela-piccinelli-stefania-sette-aida-turrini-maria-rosaria-milana2, accessed
17 Nov 2022].
Gramiccioni, L. et al. An experimental study about aluminium packaged food. In: Walker
R, Quattrucci E, editors. Nutritional and toxicological aspects of food processing: pro-
ceedings of an international symposium held at the Istituto Superiore de Sanità, Rome,
14-16 April 1987. London: Taylor & Francis; 1987:331-6.
Gramiccioni L, Ingrao G, Milana MR, et al. Aluminium levels in Italian diets and in
selected foods from aluminium utensils. Food Addit Contam 1996;13(7):767-74. https://doi.
org/10.1080/02652039609374464.
Hughes JT. Aluminium and your health. London: Rime House; 1992.
JECFA. Toxicological evaluation of certain food additives and contaminants in food.
WHO Food Additives Series 35. 1989.
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 940. 2006 [available at https://apps.who.int/iris/handle/10665/43592, accessed
17 Nov 2022].
JECFA. Safety evaluation of certain food additives and contaminants. WHO Food Addi-
tives Series 65. 2012 [available at https://apps.who.int/iris/handle/10665/44813, accessed
17 Nov 2022].
Krewski D, Yokel RA, Nieboer E, et al. Human health risk assessment for alumin-
ium, aluminium oxide, and aluminium hydroxide. J Toxicol Environ Health B Crit Rev
2007;10(SUPPL. 1):1-269. https://doi.org/10.1080/10937400701597766.
Kolbaum AE, Berg K, Müller F, et al. Dietary exposure to elements from the German pilot
total diet study (TDS). Food Addit Contam Part A Chem Anal Control Expo Risk Assess
2019;36(12):1822-36. https://doi.org/10.1080/19440049.2019.1668967.
Liukkonen-Lilja H, Piepponen S. Leaching of aluminium from aluminium dishes and
packages. Food Addit Contam 1992;9(3):213-23. https://doi.org/10.1080/02652039209374065.
Mei L, Yao T. Aluminium contamination of food from using aluminiumware. Int J Environ
Anal Chem 1993;50:1-8. https://doi.org/10.1080/03067319308027577.
Müller JP, Steinegger A, Schlatter C. Contribution of aluminium from packaging mate-
rials and cooking utensils to the daily aluminium intake. Z Lebensm Unters Forsch
1993;197(4):332-41. https://doi.org/10.1007/BF01242057.
Nagy E, Jobst K. Aluminium dissolved from kitchen utensils. Bull Environ Contam Toxicol
1994;52(3):396-9. https://doi.org/10.1007/BF00197827.
Nehring U. Aluminium release from aluminium foil containers into food. August 2018
[available at https://www.alufoil.org/files/images_alufoil/about_alufoil/Aluminium_and_
health/Aluminium-Release-from-Container/AlumniumReleaseFromAluminiumTrays-
Aug2018_EN.pdf, accessed 17 Nov 2022].
Pennington JAT, Jones JW. Dietary intake of aluminium. In: Gitelman HJ, editor. Alumin-
ium and Health: a critical review. New York: Marcel Dekker; 1989:67-70.

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Al
Metals and alloys used in food contact materials and articles

Priest ND, Newton D, Day JP, et al. Human metabolism of aluminium-26 and
gallium-67 injected as citrates. Hum Exp Toxicol 1995;14(3):287-93. https://doi.
org/10.1177/096032719501400309.
Ranau R, Oehlenschläger J, Steinhart H. Aluminium levels of fish fillets baked and grilled in
aluminium foil. Food Chem 2001;73(1):1-6. https://doi.org/10.1016/S0308-8146(00)00318-6.
Sander S, Kappenstein O, Ebner I, et al. Release of aluminium and thallium ions from
uncoated food contact materials made of aluminium alloys into food and food simulant.
PloS One 2018;13(7):e0200778. https://doi.org/10.1371/journal.pone.0200778.
Scientific Committee on Consumer Safety (SCCS). Opinion on the safety of aluminium in
cosmetic products. SCCS/1613/19.S; 2020 [available at https://op.europa.eu/en/publication-
detail/-/publication/d481c962-4e6d-11ec-91ac-01aa75ed71a1/language-en/format-PDF/
source-search, accessed 17 Nov 2022].
Scientific Committee on Health, Environmental and Emerging Risks (SCHEER). Final
Opinion on tolerable intake of aluminium with regards to adapting the migration limits for
aluminium in toys. 2017 [available at https://ec.europa.eu/health/scientific_committees/
consultations/public_consultations/scheer_consultation_04_en, accessed 17 Nov 2022].
Tietz T, Lenzner A, Kolbaum AE, et al. Aggregated aluminium exposure: risk assess-
ment for the general population. Arch Toxicol 2019;93(12):3503-21. https://doi.org/10.1007/
s00204-019-02599-z.
Turhan S. Aluminium contents in baked meats wrapped in aluminium foil. Meat Sci
2006;74(4):644-7. https://doi.org/10.1016/j.meatsci.2006.03.031.
WHO IPCS. Aluminium. Environmental Health Criteria 194. 1997 [available at https://
inchem.org/documents/ehc/ehc/ehc194.htm, accessed 17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 June 2023].

52
 Sb
Antimony (Sb)

Antimony is naturally present in the Earth’s

crust and is discharged into the air from both
natural and human-induced sources. Of the Sb
discharged into the air, 41% comes from natural
sources, i.e. soil particles transported by the wind,
volcanoes, marine aerosols, forest fires and biogenic
sources (ATSDR, 1992). Human-induced sources
of atmospheric discharge include the non-ferrous
metals industry (mines, foundries and refineries)
and coal and waste combustion. Sb is discharged
into water from industries producing and exploiting
the element and its compounds (ATSDR, 1992).

Sources and levels of intake

Antimony is detected in most foods. The highest concentrations were meas-
ured in meat products (9.9 µg/kg), sugar (8.8 μg/kg), chocolate (4.2 μg/kg),
cakes (3.8 μg/kg) and fish (2.6 µg/kg) (ANSES, 2011).
In the 2014 UK Total Diet Study, the highest total mean and 97.5th percen-
tile exposures were in the age class 1.5 to 3 years and were 0.031-0.073 μg/kg
bw/day and 0.065-0.12 μg/kg bw/day, respectively. The highest contributing
food group to total mean exposure was ‘Milk’ with a total mean exposure
of 0.0098 μg/kg bw/day (FSA, 2014). ANSES (2011) estimated mean daily
intake at 0.03 μg/kg bw/day in adults and 0.04 μg/kg bw/day in children.

53
 Metals and alloys used in food contact materials and articles
Sb

Metallic food contact materials

Antimony is used in the manufacture of tin alloys (it hardens the alloy) to
produce pewter alloy (e.g. Britannia metal).
European Standard EN 610:1995 applies to tin and tin alloy items coated
exclusively with tin or tin alloy, or partly tin-plated materials that, as fin-
ished products, recurrently come into direct contact with food. It also
defines an SML for antimony (0.01 mg/kg).
Antimony can be found as an impurity in aluminium alloys and tin.
In France, a maximum permissible antimony content of 2.5% is specified in
Fiche MCDA n°1 (V02 – 01/04/2017).

Other food contact materials

Antimony is used in fire-proofing agents in textiles and plastic materi-
als where antimony trioxide acts as a synergist with organochlorine and
bromated compounds. It is further used as an opacifying agent in glass,
ceramics and enamels, as a pigment in colourants and as a chemical cata-
lyst (IARC, 1989).

Release
During storage of mineral water in PET bottles, the catalyst antimony tri-
oxide (Sb2O3, which exists in dimerised form) migrates and concentrates in
proportion to the time spent in the mineral water (Shotyk, 2006). Concen-
trations (< 1 ppb) are always below the recommended maximum rates, and
therefore do not raise concern.

Safety aspects
• WHO (2022) set a guideline value of 0.02 mg/L derived from a TDI of
0.006 mg/kg bw/day (0.36 mg/day). This value was based on a NOAEL
of 6 mg/kg bw/day from a subchronic, drinking-water study in rats, pre-
senting decreased bw gain and reduced food and water intake. An uncer-
tainty factor of 1 000 (100 for intraspecies and interspecies variation and

54
 Antimony (Sb)

Sb
10 for the use of a subchronic study) was applied to the NOAEL, resulting
in the TDI of 0.006 mg/kg bw/day (WHO, 2003).
• EFSA (2004) set an SML of 0.04 mg/kg for antimony based on the
TDI derived by WHO. This value was also adopted by Regulation
(EU) No 10/2011.

Conclusions and recommendations

the SRL for antimony is set at 0.04 mg/kg food or food simulant

The SRL was derived from the TDI of 0.006 mg/kg bw/day (0.36 mg/day)
assessed by WHO (2003, 2022). Depending on the metallic material, anti-
mony can be considered either as an alloying constituent or an impurity. In
order not to weaken consumer protection, it was concluded that an allow-
ance of 10% of the TRV was reasonable. Therefore, assuming that a person
of 60 kg bw consumes 1 kg of foodstuffs per day that is packaged and/or
prepared with FCM made from metals and alloys, the SRL for antimony is
set at 0.04 mg/kg.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 17 Nov 2022].
ATSDR. Toxicological profile for antimony and compounds. US Department of Health
and Human Services. 1992 [available at https://www.atsdr.cdc.gov/ToxProfiles/tp23.pdf,
accessed 17 Nov 2022].
Direction générale de la consommation, de la concurrence et de la répression des fraudes
(DGCCRF). Fiche MCDA n°1 (V02 – 01/04/2017). Aptitude au contact alimentaire des
métaux et alliages destinés à entrer en contact avec des denrées alimentaires [Food contact
suitability of metals and alloys]. 2017 [available at https://www.economie.gouv.fr/files/files/
directions_services/dgccrf/securite/produits_alimentaires/materiaux_contact/fiches-
metaux-alliages-v2.pdf, accessed 17 Nov 2022].
EFSA. Opinion of the Scientific Panel on Food Additives, Flavourings, Processing Aids
and Materials in Contact with Food (AFC) on a request from the Commission related to
a 2nd list of substances for food contact materials. EFSA Journal 2004;24:1-13. https://doi.
org/10.2903/j.efsa.2004.24a.

55
 Metals and alloys used in food contact materials and articles
Sb

CEN. Tin and tin alloys. Ref: EN 610:1995.

EC. Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and
articles intended to come into contact with food. Official Journal of the European Union
2011;54:1-89.
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/sites/default/files/media/
document/measurement-of-the-concentrations-of-metals-and-other-elements-from-the-
2014-uk-total-diet-study.pdf, accessed 17 Nov 2022].
Shotyk, W.; Krachler, M.; Chen, B. (2006). Contamination of Canadian and European
bottled waters with antimony from PET containers. J Environ Monit 2006;8(2):288-92.
https://doi.org/10.1039/b517844b.
WHO, International Agency for research on cancer (IARC). IARC monographs on the
evaluation of carcinogenic risks to humans. Vol. 47, 1989. Available at: https://monographs.
iarc.who.int/wp-content/uploads/2018/06/mono47.pdf, accessed 21 March 2023.
WHO. Antimony in drinking-water. Background document for development of WHO
Guidelines for Drinking-water Quality. WHO/SDE/WSH/03.04/74; 2003 [available
at https://cdn.who.int/media/docs/default-source/wash-documents/wash-chemicals/
antimony.pdf?sfvrsn=e1e9a0a6_4, accessed 17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

56
 Chromium (Cr)

Cr
Chromium is found mainly in the trivalent form
in the environment. Hexavalent chromium, or
chromate, may also be found in very small amounts,
usually arising from anthropogenic sources (Beliles,
1994), or present in minerals and rocks in countries
such as Greece and Italy (Kazakis et al., 2015). Cr(III)
has the ability to form strong, inert complexes with
a wide range of naturally occurring organic and
inorganic ligands (Florence et al., 1980). In most
soils and bedrocks, chromium is immobilised in
the trivalent state (Florence et al., 1980). Cr(III)
is an essential element to humans. Chromium is
found at low levels in most biological materials.

Sources and levels of intake

The main sources of chromium are cereals, meat, vegetables, white fish
and vegetable oil, while fruits contain smaller amounts (EVM, 2003).
Most foodstuffs contain less than 0.1 mg/kg of chromium (EVM, 2003;
Oskarsson and Sandström, 1995). Chromium is present in the diet mainly
as Cr(III) (EVM, 2003). According to the EVM (2003), most of the chro-
mium in food originates from food processing using stainless steel food
processors and containers. The EFSA CONTAM Panel decided to consider
all the reported analytical results of chromium in food as Cr(III). This
assumption was based on the outcome of recent speciation work, the fact
that food is by-and-large a reducing medium, and that oxidation of Cr(III)
to Cr(VI) would not be favoured in such a medium (EFSA, 2014).

57
 Metals and alloys used in food contact materials and articles

Dietary intake of chromium from food sources in multiple European coun-

tries ranges between 61 and 160 μg/day for adults, with an upper intake of
580 μg/person/day (EFSA, 2010).
Cr

Chronic dietary exposure to Cr(III) was estimated combining the food

mean occurrence data with the food consumption data at the individ-
ual level. Overall mean human chronic dietary exposure ranged from
a minimum LB of 0.6 to a maximum UB of 5.9 μg/kg bw/day. The 95th
percentile dietary exposure values ranged from 1.1 (minimum LB) to 9.0
(maximum UB) μg/kg bw/day. The adult populations showed lower expo-
sure to Cr(III) than the younger populations (EFSA, 2014).
ANSES (2011) estimated mean daily intake of total chromium [sum of
Cr(III) and Cr(VI)] at 277 µg/person/day in adults and 223 µg/person/day
in children.

Metallic food contact materials

Chromium is found in some types of cans and utensils. In cans, it serves to
passivate tinplate surfaces. Chromium is used in the production of stain-
less steel of various kinds and in alloys with iron, nickel and cobalt. Ferro-
chromium, an alloy of chromium and iron, is produced by direct reduction
of the chromite ore and used primarily in manufacturing stainless steel
and heat-resistant steel (Sun and Costa, 2022). All stainless steels contain
chromium (minimum 10.5% – see section on Main types of alloys) and they
are important FCM used for transportation (e.g. in milk trucks), for pro-
cessing equipment (e.g. in the dairy and chocolate industry, in processing
of fruit such as apples, grapes, oranges and tomatoes), for containers such
as wine tanks, for brew kettles and beer kegs, for processing of dry food
such as cereals, flour and sugar, for utensils such as blenders and bread-
dough mixers, in slaughterhouses, in the processing of fish, for nearly all
of the equipment in professional kitchens such as restaurants and hospitals,
in electric kettles, cookware and kitchen appliances of all kinds, for bowls,
knives, spoons and forks. Chromium is also used to coat other metals,
which are then protected from corrosion because of the passive film that
forms on the surface of chromium.

58
 Chromium (Cr)

Other food contact materials

Chromium is contained in pigments used for coloured glazes and for metal

Cr
finishing (Sun and Costa, 2022).

Release
Limited information on the release of chromium from metals and alloys
used in FCM and articles was available before the publication of this Tech-
nical Guide. In one study a comparison was performed between meals pre-
pared in different stainless steel and glass pans. The amount of chromium
measured in stainless steel-cooked meals was higher for some, but not for
others when compared to glass-cooked meals (Accominotti et al., 1998).
Another study investigated the release of chromium from different stain-
less steel pots using cold and boiling 5% acetic acid. While, with one excep-
tion, no chromium was measured when cold acetic acid was used, release
into boiling acetic acid after 5 min ranged between 0.010 and 0.315 mg/kg
(Kuligowski and Halperin, 1992). Further, in a market survey of stainless
steel cutlery conducted by the German surveillance authorities, elevated
levels of chromium of up to 43 mg/L were detected. The release was tested
with 3% acetic acid for 2 hours at 70°C. It was noted by the authorities
that, in particular, cheap, low-quality cutlery showed the highest release
(CVUA-OWL, 2009).
Release of chromium from a range of seven stainless steel grades used as
FCM was examined (using food simulant 5 g/L citric acid, pH 2.4 and 1 cm2
in 2 mL test medium) after exposure for 2 hours at 70°C followed by 24
and 238 hours at 40°C. Chromium release for all stainless steel grades and
test conditions investigated were below the applicable SRL (0.25 mg/kg)
and did not exceed 0.2 µg/cm2. Chromium was released in its trivalent
form (Hedberg et al., 2014). The study was extended using as-received and
pre-passivated 6 cm2 specimens and three different simulants; artificial
tap water, 5 g/L citric acid and 5 g/L citric acid + 0.5 M NaCl (conditions:
2 hours at 70°C followed by 10 days at 40°C). Chromium release was close to
the detection limits for all grades in artificial tap water. Higher release was
observed in citric acid, but did not exceed the SRL and release was noted to
reduce with time (Mazinanian et al., 2016).

59
 Metals and alloys used in food contact materials and articles

Another study assessed the release of chromium into tomato sauce and
lemon marmalade from 18/10 stainless steel pots from different manu-
facturers. Cooking conditions were 1 hour with or without added EDTA;
Cr

aqueous solutions at pH 2.3, 7.7 and 9 were also boiled for 1 hour in the
same pots. The release of chromium increased with cooking/boiling time,
was higher with unused pots, at low pH or with EDTA, and was noted to
vary between manufacturers but was in all cases found below 0.3 mg/kg
(Guarneri et al., 2017).
Nickel-chromium electroplated articles should also be tested for nickel
release. (Whittington et al., 2015).

Safety aspects
• JECFA has not evaluated chromium.
• WHO (2022) established a guideline value of 0.05 mg/L for total chromium.
• The speciation of chromium is of great importance for toxicity. Cr(III), the
most stable oxidation state in biological materials, is an essential element
for normal glucose metabolism, whereas Cr(VI) is highly toxic (Beliles,
1994; Costa, 1997; Oskarsson and Sandström, 1995). Cr(III) has low toxic-
ity due to low absorption (about 0.5%) (Oskarsson and Sandström, 1995).
Toxic aspects of chromium are related to Cr(VI), due to its high absorp-
tion, easy penetration of the cell membranes and its genotoxicity and oxi-
dising properties (Oskarsson and Sandström, 1995).
• The SCF (2003) concluded in its opinion on the tolerable upper level of
trivalent chromium for foods for particular nutritional uses and for food
supplements, that there was no evidence of adverse effects associated
with supplementary intake of chromium up to a dose of 1 mg/day.
• WHO (1996) considers that chromium supplementation should not
exceed 250 µg/day.
• The EVM (2003) assessed chromium but were unable to establish a
safe upper level for intake. However, 0.15 mg Cr(III)/kg bw/day was not
expected to result in adverse effects. This is based on a dose of 15 mg
Cr/kg bw/day, administered as chromium chloride to rats that did not

60
 Chromium (Cr)

show adverse effects. An uncertainty factor of 100 was used (10 for inter-
species and 10 for intraspecies variation). This guidance applies to Cr(III)
compounds only and excludes chromium picolinate (a synthetic chro-

Cr
mium compound with higher solubility and lipophilicity than other
Cr(III) compounds, which has been shown to cause DNA damage in
mammalian cells in vitro).
• In 2010, the EFSA Panel on Food Additives and Nutrient Sources added
to Food (ANS) stated that ‘a tolerable upper limit for chromium is not
available’. They noted that both the limit of 1 mg chromium/day proposed
by the SCF and of 250 μg chromium/day for supplementation proposed
by WHO were based on studies that were not designed to test the safety of
chromium. The Panel also noted that an intake of 250 μg chromium/day
from supplementation would be in the range of intake of chromium from
the regular diet. Therefore, they concluded that ‘until more is known
about chromium, the value set by WHO seems most adequate to limit
the intake of chromium from foods for particular nutritional uses and
foods intended for the general population (including food supplements).’
• According to ICH Q3D(R1), the oral chromium PDE is 10 700 µg/day.
Sources of chromium in pharmaceuticals may include colorants, leach-
ing from equipment or container closure systems, and catalysts. Except
when it is used as a catalyst, intake of chromium from pharmaceuticals
will be in the form of metallic chromium (Cr or Cr(III) rather than the
more toxic Cr(VI)); therefore, for drug products, this safety assessment
is based on the known toxicity of Cr(III) and Cr(VI) is excluded from
the assessment. In 2014, the EFSA CONTAM Panel derived a TDI of
0.3 mg/kg bw/day for Cr(III) from the lowest NOAEL identified in an
NTP chronic oral toxicity study in rats. Under the assumption that all
chromium in food is Cr(III), the mean and 95th percentile of dietary
exposure across all age groups were well below the TDI and therefore
do not raise concerns for public health. In the case of drinking water,
the Panel considered all chromium in water as Cr(VI) and a BMDL10 of
1 mg/kg bw/day from a carcinogenicity study in mice as an appropriate
starting point for MOE calculation. The calculated MOEs are mainly
above 10 000 and hence indicate low concern regarding Cr(VI) intake

61
 Metals and alloys used in food contact materials and articles

via drinking water (water intended for human consumption and natural
mineral waters) for all age groups.
Cr

Conclusions and recommendations

the SRL for chromium is set at 1 mg/kg food or food simulant

Considerations for Cr(VI)

In water: data from the literature (Mazinanian et al., 2016) and member
state official control laboratories indicate that release of total chromium in
water is negligible. Therefore, release of Cr(VI) from stainless steel FCMs
into water can be considered negligible.
In food: EFSA considered as a reasonable assumption that all chromium in
food is in the form of Cr(III). Therefore, any released chromium in food can
be assumed to be released as Cr(III) and not further oxidise to Cr(VI). In
summary, based on the current state of the art, the adoption of an SRL for
Cr(VI) is not necessary. However, EFSA (2014) recommends that further
data for the characterisation of Cr(VI) reduction in the gastrointestinal
tract at doses relevant for human exposure should be generated.

Considerations for Cr(III)

Taking into account the TDI of 0.3 mg/kg bw/day for Cr(III) that was
derived by EFSA (2014), a 20% allocation factor and the conventional
assumption that a person of 60 kg bw consumes 1 kg of foodstuffs per day
that is packaged and/or prepared using FCM made from metals and alloys,
the SRL for Cr(III) could be set at up to 3.6 mg/kg food. However, based on
the current state of the art in the production of FCM, the limit of 1 mg/kg
is fully achievable. In line with GMP, the SRL for total Cr is set at 1 mg/kg.
Release of Cr into water should be monitored for FCMs intended to be used
in contact with water. To ensure a MOE above 10 000, the release of Cr(VI)
should not exceed 0.006 mg/L (BMDL10 of 1 mg/kg bw/day, a MOE of 10 000,
a person of 60 kg bw consuming 1 litre water per day). Therefore, if the
concentration of total chromium released in water exceeds 0.006 mg/kg,
further investigation of Cr(VI) release is recommended.

62
 Chromium (Cr)

References
Accominotti M, Bost M, Haudrechy P, et al. Contribution to chromium and nickel

Cr
enrichment during cooking of foods in stainless steel utensils. Contact Dermatitis
1998 ;38(6) :305-10. https://doi.org/10.1111/j.1600-0536.1998.tb05763.x.
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
Chemisches und Veterinäruntersuchungsamt Ostwestfalen-Lippe (CVUA-OWL).
Jahresbericht 2009 [Annual Report 2009] [available at https://cvua-owl.de/service/
veroeffentlichungen/jahresberichte/65-cvua-jb-2009/download, accessed 17 Nov 2022].
Costa M. Toxicity and carcinogenicity of Cr(VI) in animal models and humans. Crit Rev
Toxicol 1997;27(5):431-42. https://doi.org/10.3109/10408449709078442.
EFSA. Scientific Opinion on the safety of trivalent chromium as a nutrient added for
nutritional purposes to foodstuffs for particular nutritional uses and foods intended for
the general population (including food supplements). EFSA Panel on Food Additives
and Nutrient Sources added to Food (ANS). EFSA Journal 2010;8(12):1882. https://doi.
org/10.2903/j.efsa.2010.1882.
EFSA. Scientific Opinion on the risks to public health related to the presence of chro-
mium in food and drinking water. EFSA Journal 2014;12(3):3595. https://doi.org/10.2903/j.
efsa.2014.3595.
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
Florence TM, Batley GE, Benes P. Chemical speciation in natural waters. Crit Rev Anal
Chem 1980;9:3:219-96. https://doi.org/10.1080/10408348008542721.
Guarneri F, Costa C, Cannavò SP, et al. Release of nickel and chromium in common foods
during cooking in 18/10 (grade 316) stainless steel pots. Contact Dermatitis 2017;76(1):40-8.
https://doi.org/10.1111/cod.12692.
Hedberg Y, Mazinanian N, Wallinder IO. Compliance tests of stainless steel as a food
contact material using the CoE test guideline. KTH Royal Institute of Technology. Decem-
ber 2014 [available at http://bit.ly/1USTJjn, accessed 17 Nov 2022].
ICH. Guideline for elemental impurities Q3D(R1). March 2019 [available at https://database.
ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_Guideline_2019_0322.pdf,
accessed 17 Nov 2022].
Kazakis N, Kantiranis N, Voudouris KS, et al. Geogenic Cr oxidation on the surface of
mafic minerals and the hydrogeological conditions influencing hexavalent chromium
concentrations in groundwater. Sci Total Environ 2015;514:224-38. https://doi.org/10.1016/j.
scitotenv.2015.01.080.

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 Metals and alloys used in food contact materials and articles

Kuligowski J, Halperin KM. Stainless steel cookware as a significant source of nickel, chro-
mium, and iron. Arch Environ Contam Toxicol 1992;23(2):211-15. https://doi.org/10.1007/
BF00212277.
Cr

Sun H and Costa M. Chromium. In: Nordberg GF, Costa M, editors. Handbook on the
toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
2022.
Mazinanian N, Herting G, Odnevall Wallinder I, et al. Metal release and corrosion resist-
ance of different stainless steel grades in simulated food contact. Corrosion 2016;72(6):775-
90. https://doi.org/10.5006/2057.
Oskarsson A, Sandström B. A Nordic project – Risk evaluation of essential trace elements:
essential versus toxic levels of intake. Analyst 1995 120(3):911-12. https://doi.org/10.1039/
an9952000911.
SCF. Nutrient and Energy Intakes for the European Community. Reports of the Scien-
tific Committee for Food. 1993 [available at https://food.ec.europa.eu/system/files/2020-12/
sci-com_scf_out89.pdf, accessed 17 Nov 2022].
SCF. Opinion of the SCF on the Tolerable Upper Intake Level of Trivalent Chromium.
SCF/CS/NUT/UPPLEV/67 April 2003 [available at https://ec.europa.eu/food/fs/sc/scf/
out197_en.pdf, accessed 17 Nov 2022].
Whittington CM, Lo WY, Yau MY. Prevention of nickel release from decorative nick-
el-chromium electroplated articles in the context of allergic contact dermatitis. Trans Inst
Met Finish 2015;93(4):176-9. https://doi.org/10.1179/0020296715Z.000000000253.
WHO. Trace elements in human nutrition and health. 1996 [available at https://apps.who.
int/iris/handle/10665/37931, accessed 17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

64
 Cobalt (Co)

Co
Cobalt is a rare element composing about
0.001% of the Earth’s crust, often occurring
in association with nickel, silver, lead, copper
and iron ores (Lison, 2022). Cobalt is present
in the vitamin cobalamin or vitamin B12.

Sources and levels of intake

Cobalt is normally found in very low concentrations in foodstuffs (approx-
imately 0.01-0.05 mg/kg) (Beliles, 1986), mainly in green leafy vegetables.
Common plants such as lettuce, beets, cabbage, spinach and sweet potatoes
act as sources of dietary cobalt, with spinach containing 0.1-0.7 mg/kg on a
moisture-free basis (Beliles, 1994).
ANSES (2011) estimated mean daily intake at 0.18 µg/kg bw/day in adults
and 0.31 µg/kg bw/day in children.

Metallic food contact materials

A major use of cobalt is in the production of steel and alloys of a high
melting point and resistant to oxidation (Lison, 2022). It can account for
between 0.05% and 0.1% of the composition of certain steels.

Other food contact materials

In the glass and ceramic industries, small quantities of cobalt oxide are
used to neutralise the yellow tint resulting from the presence of iron in glass,
pottery and enamels. Larger quantities are used to impart a blue colour to

65
 Metals and alloys used in food contact materials and articles

these products (Beliles, 1994). Cobalt oxide is used in enamel coatings on

steel to improve the adherence of the enamel to the metal (Beliles, 1994).

Release
Co

Cobalt is a relatively non-reactive metal and it does not oxidise in dry or

moist air (Beliles, 1994). Cobalt reacts with most acids, but becomes passive
in concentrated nitric acid. Cobalt is not attacked by alkalis, either in solu-
tion or when fused, but it combines with halogens when heated (Beliles,
1994).

Safety aspects
• Cobalt is an essential element as a constituent of vitamin B12. The human
body (adult, 70 kg) contains on the average 1.1 mg cobalt, 85% of which
is in the form of vitamin B12 (Lison, 2022). Oral bioavailability of inor-
ganic cobalt compounds is reported to vary from 5-45% (Lison, 2022). A
marginal part of refined cobalt is used in fertilisers, since a low cobalt
concentration in soil may cause cobalt deficiency in sheep and cattle
(Lison, 2022). Even though cobalt is essential to humans and animals, a
few cases of poisoning have been recorded. Heart failure, polycythemia
and thyroid lesions are common findings and, in the worst cases, death
were seen after intakes of cobalt via large amounts of contaminated beer
(cobalt is used to prevent fermentation) (Lison, 2022).
• SCF (1993) Scientific opinion on vitamin B12 recommends that daily
intake should not exceed 0.2 mg/day.
• EFSA (2003) confirmed, in an opinion on oleic acid, cobalt salt, the classi-
fication of cobalt in SCF-List 3 with a restriction of 0.05 mg/kg. This value
has been adopted in Regulation 10/2011 and was derived by the Dutch
RIVM in 1991 based on estimates of total daily intakes.
• In 2003, cobalt was assessed by the EVM. While there was insufficient
data to establish a safe upper level, they suggested an intake of 0.023 mg/kg
bw/day would not be expected to produce adverse effects. This was based
on animal data showing minor testicular effects at 23 mg Co/kg bw/day

66
 Cobalt (Co)

with a total uncertainty factor of 1 000 (10 for extrapolation from a LOAEL
to a NOAEL and 10 for interspecies and 10 for intraspecies variation).
• RIVM (2001) derived a TDI of 0.0014 mg/kg bw/day (0.08 mg/person/day)
from human data, in which an additional effect from alcohol consump-
tion in the study population was possible.

Co
Conclusions and recommendations
the SRL for cobalt is set at 0.02 mg/kg food or food simulant

The TDI established by RIVM in 2001 was derived from human data. Since
European intake data are scarce, the default allowance of 20% for expo-
sure through FCM and articles made from metals and alloys was applied
to the TDI of 0.0014 mg/kg bw/day. Assuming that a person of 60 kg bw
consumes 1 kg of foodstuffs per day that is packaged and/or prepared with
FCM made from metals and alloys, the SRL for cobalt is set at 0.02 mg/kg.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial hygiene and
toxicology. 4th edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
EFSA. Opinion of the Scientific Panel on Food Additives, Flavourings, Processing Aids
and Materials in Contact with Food (AFC) on a request from the Commission related to
a 1st list of substances for food contact materials. EFSA Journal 2003;1(12):3. https://doi.
org/10.2903/j.efsa.2003.3.
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
EC. Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and
articles intended to come into contact with food. Official Journal of the European Union
2011;54:1-89.
Lison D. Cobalt. In: Nordberg GF, Costa M, editors. Handbook on the toxicology of metals.
Volume II, Specific metals. 5th edition. Amsterdam: Academic Press; 2022. https://doi.
org/10.1016/B978-0-12-822946-0.00008-8.

67
 Metals and alloys used in food contact materials and articles

RIVM. Voorstel voor de humaan-toxicologische onderbouwing van C-(toetsings)waarden

[Proposal for the toxicological basis for the determination of C-values]. RIVM Report
725201005. 1991 [available at https://www.rivm.nl/bibliotheek/rapporten/725201005.html,
accessed 17 Nov 2022].
RIVM. Re-evaluation of human-toxicological maximum permissible risk levels. RIVM
Report 711701 025. 2001 [available at https://www.rivm.nl/bibliotheek/rapporten/711701025.
Co

pdf, accessed 17 Nov 2022].

SCF. Nutrient and Energy Intakes for the European Community. Reports of the Scien-
tific Committee for Food. 1993 [available at https://food.ec.europa.eu/system/files/2020-12/
sci-com_scf_out89.pdf, accessed 17 Nov 2022].

68
 Copper (Cu)

Copper is found at a concentration of 70 mg/kg

Cu
in the Earth’s crust (Beliles, 1994). It exists in two
oxidation states: Cu(I) (cuprous) and Cu(II) (cupric),
although it can also occur in a trivalent state due
to certain chemical reactions. Copper is amongst
the most effective of metal biochemical oxidising
agents. It is an essential yet toxic trace element
(Birk Møller and Aaseth, 2022). Copper also has the
ability to restrict bacterial growth, e.g. Legionella
in drinking water systems (Rogers et al., 1994).

Sources and levels of intake

Copper is naturally present in most foodstuffs in the form of copper ions or
copper salts. Generally, the concentration of copper in foodstuffs is about
2 mg/kg or less, the main sources being meat, offal, fish, fruits, nuts and
green vegetables (Birk Møller and Aaseth, 2022). However, levels of up to
39 mg/kg have been reported for liver and cocoa.
In the European Union Risk Assessment Report, copper exposure from
food and beverages, estimated from a wide range of duplicate diet studies
and market basket analysis consistently shows copper intakes of < 2 mg/day.
An overall median copper intake of 1.25 mg Cu/day was derived (EU-RAR,
2008).
ANSES (2011) estimated mean daily intake at 1.94 mg/person/day in adults
and the 95th percentile at 4.1 mg/person/day.
EFSA (2015) derived AIs based on observed intake in several EU countries.
Mean copper intakes in eight EU countries ranged from 1.27 to 1.67 mg/day
in men aged 18 years and older and from 1.15 to 1.44 mg/day in non-pregnant

69
 Metals and alloys used in food contact materials and articles

women aged 18 years and older. They noted that there was insufficient
evidence at the time to set different dietary reference values according to
age in adults, but decided to set different AI values for women (1.3 mg/day
or 1.5 mg/day for pregnant and lactating women, respectively) and men
(1.6 mg/day), as intakes are lower for women. Similarly, based on the
observed intakes they concluded the following AIs for infants (0.4 mg/day),
for boys and girls aged 1 to < 3 years (0.7 mg/day), for boys and girls aged 3
to < 10 years (1.0 mg/day), for boys aged 10 to < 18 years (1.3 mg/day) and for
Cu

girls aged 10 to < 18 years (1.1 mg/day).

Additionally, exposure to copper via dietary supplements can contribute up
to 2 mg/day to the total intake (EU-RAR, 2008).

Metallic food contact materials

Copper vessels are traditionally used in many specialised food process-
ing activities, such as in breweries and distilleries, for cheese, chocolate,
dry vegetable, jam and sweet production. In general, copper is used unal-
loyed for food utensils, for example in saucepans, which are usually lined
inside with tin or stainless steel. Copper is used in alloys, particularly brass,
bronze and nickel silver.

Other food contact materials

Powders, flakes and fibres of brass, bronze, copper, stainless steel, tin, iron
and alloys of copper, tin and iron (FCM number 80), copper iodide (FCM
number 412), copper bromide (FCM number 523), or copper hydroxide
phosphate (FCM number 972) are authorised for use as additives in plastic
FCM under Regulation (EU) No 10/2011, with a limit of migration set at
5 mg/kg food.

Release
Copper is slowly attacked by dilute hydrochloric acid or dilute sulfuric
acid and is soluble in ammonia water (Beliles, 1994). Acidic foodstuffs can
attack copper in utensils. Therefore, copper may be present in foodstuffs

70
 Copper (Cu)

due to release from FCM, copper utensils, copper pipes, etc., or from using
drinking water from copper pipes for food preparation. In some cases, high
copper release may induce some discolouration.

Safety aspects
• JECFA (1982) established a PMTDI of 0.5 mg/kg bw/day from all sources
and set a dietary requirement of 0.05 mg/kg bw/day.

Cu
• WHO (2022) set a guideline value for copper at 2 mg/L in drinking water.
• There is greater health risk from a copper deficiency than from excess
copper intake. Acute toxicity due to ingestion of copper is infrequent in
humans. However, when it occurs it is usually a consequence of the release
of copper into beverages (including drinking water) or from accidental or
deliberate ingestion of high quantities of copper salts. Symptoms include
vomiting, lethargy, acute haemolytic anaemia, renal and liver damage,
neurotoxicity, increased blood pressure and respiratory rates. In some
cases, coma and death ensued (IPCS/WHO, 1996).
• The SCF (2003) derived a tolerable upper limit for adults of 5 mg/person/day
from a dietary supplementation study, which EFSA adopted as upper
limit in 2006. This value arose from a copper dose of 10 mg/day, where
no adverse effects were detected, and an uncertainty factor of 2 for popu-
lation variability. For children aged 1-3 years, an upper limit of 1 mg/day
was derived, taking into consideration their lower bw. In the context of
the peer review process of plant protection products, EFSA (2008) estab-
lished an ADI of 0.15 mg Cu/kg bw per day (corresponding to 10 mg/day
for a 70-kg adult). This ADI value was confirmed by EFSA in 2018.
• The EVM (2003) assessed copper and derived a safe upper level of
0.16 mg/kg bw/day based on a NOAEL of 16 mg/kg bw/day in a subchronic
rat toxicity study and using an uncertainty factor of 100.
• According to ICH Q3D(R1), the oral PDE for copper is 3 400 µg/day.
Copper compounds (e.g. copper chromite) are used as catalysts in hydrog-
enolysis and decarboxylation reactions.

71
 Metals and alloys used in food contact materials and articles

• In 2008, the copper industry submitted a voluntary risk assessment report

to the EC, which was evaluated by the Technical Committee for New and
Existing Substances (TCNES) and the Scientific Committee for Health
and Environmental Risk (SCHER). A NOAEL of 16.3 mg/kg bw/day was
derived from a 90 day subchronic rat study, which was also confirmed
by a two generation rat reproductive toxicity study. After applying an
uncertainty factor of 100, 0.16 mg/kg bw/day was set as (derived) NOAEL,
corresponding to 11.4 mg/day for a person of 70 kg bw (EU-RAR, 2008).
Cu

Conclusions and recommendations

the SRL for copper is set at 4 mg/kg food or food simulant

This SRL was derived from the ADI of 0.15 mg/kg bw/day (10 mg/day)
assessed by EFSA (2008, 2018). The intake data were used to estimate a
worst-case oral exposure to copper. Assuming a worst-case intake from
food/drinking water at the 95th percentile of 4 mg/day and an additional
intake from copper supplements of 2 mg/day, a total intake of 6 mg/day
can be calculated. Since this worst-case intake is below the toxicologically
derived limit of 9.8 mg/day, the difference can be allocated to exposure
from FCM made from metals and alloys.
Consequently, assuming that a person of 60 kg bw consumes 1 kg of food-
stuffs per day that is packaged and/or prepared with FCM made from
metals and alloys, the SRL for copper is set at 4 mg/kg.
Children were not considered as a vulnerable sub-population as done by
the SCF (2003) and EFSA (2006) because of the negligible exposure of chil-
dren to FCM and articles made out of copper (Foster et al., 2010).
Release due to traditional use, as outlined earlier, falls outside the scope of
this SRL.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].

72
 Copper (Cu)

Beliles RP. The metals. In: Clayton GD, Clayton FE. Patty’s Industrial hygiene and toxicol-
ogy. 4th edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
Birk Møller L and Aaseth A. Copper. In: Nordberg GF, Costa M, editors. Handbook on the
toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
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[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
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EFSA. Conclusion regarding the peer review of the pesticide risk assessment of the active

Cu
substance copper compounds. EFSA Journal 2008;6(10):187r. Available at https://doi.
org/10.2903/j.efsa.2008.187r.
EFSA. Scientific Opinion on Dietary Reference Values for copper. NDA. EFSA Journal
2015;13(10):4253. https://doi.org/10.2903/j.efsa.2015.4253.
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pounds copper(I), copper(II) variants namely copper hydroxide, copper oxychloride,
tribasic copper sulfate, copper(I) oxide, Bordeaux mixture. EFSA Journal 2018;16(1):5152.
Available at https://doi.org/10.2903/j.efsa.2018.5152.
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the Council of 27 October 2004 on materials and articles intended to come into contact
with food and repealing Directives 80/590/EEC and 89/109/EEC. Official Journal of the
European Union 2004;47:4-17.
European Commission. Commission Regulation (EU) No 10/2011 of 14 January 2011 on
plastic materials and articles intended to come into contact with food. Official Journal of
the European Union 2011;54:1-89.
European Risk Assessment Report (EU-RAR). Copper Voluntary Risk Assessment Report.
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Rogers J, Dowsett AB, Dennis PJ, et al. Influence of plumbing materials on biofilm forma-
tion and growth of Legionella pneumophila in potable water systems. Appl Environ Micro-
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SCF. Opinion of the SCF on the Tolerable Upper Intake Level of Copper. March 2003 [available
at http://ernaehrungsdenkwerkstatt.de/fileadmin/user_upload/EDWText/TextElemente/
Ernaehrungswissenschaft/Naehrstoffe/Kupfer_EUGuidelinetolerableUpperlevel.pdf,
accessed 17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
Cu

01 July 2023].

74
 Iron (Fe)

Iron is the fourth most abundant element (5%) in

the Earth’s crust (Tenenbein and Huang, 2022). Iron
is used for the production of steel. The principal
compounds of iron are ferrous Fe(II) and ferric Fe(III)

Fe
(Beliles, 1994). Iron is essential for the synthesis of
blood pigments. Under normal conditions the body
contains about 4 g of iron (Beliles, 1994). Haemoglobin
contains the greatest amount of iron in the body (67%),
and this is largely in the red blood cells (Beliles, 1994).

Sources and levels of intake

Iron is present in most foods and beverages. In general, the iron content of
foodstuffs varies greatly from iron-rich foods such as red meat to extraordi-
narily iron-poor foods such as milk (Tenenbein and Huang, 2022). Within
the EU, the fortification of foods with iron is foreseen by Regulation (EC)
No 1925/2006. Some countries have specific legislation for the fortifica-
tion of specific foods such as wheat flour in order to provide the necessary
amount of iron in the diet (Oskarsson and Sandström, 1995; and UK Statu-
tory Instrument No 141, 1998).
Mean dietary intakes in various European countries range from 10 to
22 mg/day and the 97.5th percentile from 16 to 72 mg/day (SCF, 1993; EFSA,
2006).
ANSES (2011) estimated mean daily intake at 7.71 mg/person/day in adults
and 6.57 mg/person/day in children.

75
 Metals and alloys used in food contact materials and articles

Metallic food contact materials

Iron is used in a great variety of kitchen utensils. It is found in steel cans
and in lids and closures for glass bottles and jars. Cast iron is also used for
pots and pans. Iron is the major constituent of steel, which also contains
small quantities of certain other metals, such as chromium, manganese,
molybdenum and nickel. Steel is the most recycled material on the planet
(Tenenbein and Huang, 2022).

Other food contact materials

Fe

Several forms of iron oxide are used as paint pigments (Beliles, 1994), of
which some are also permitted as food colourings. The soluble salts are
variously used as pigments in FCM (Beliles, 1994).

Release
Food contamination by iron may originate from food processing equip-
ment, containers and other utensils used for foodstuffs. Tests performed on
various stainless steel saucepans using boiling 5% acetic acid as a simulant
and a contact time of 5 minutes resulted in iron release of 0.22-2.85 mg/kg
(Kuligowski and Halperin, 1992). Similarly, a survey of teapots showed iron
release of between 0.1 mg/L and 4.7 mg/L using a citric acid solution (1 g/L)
as a simulant and a contact time of 30 minutes (Bolle et al., 2011). Rare cases
of release of very high quantities of iron from FCM such as iron kitchen
utensils have been observed. For example, the release of 2 500 mg/kg iron
from a wok and a cast iron skillet were observed under the conditions men-
tioned above (Kuligowski and Halperin, 1992).

Safety aspects
• JECFA (1983) established a PMTDI of 0.8 mg/kg bw/day. The value applies
to iron from all sources, except for iron oxides used as colouring agents,
supplemental iron taken during pregnancy and lactation and supplemen-
tal iron for specific clinical requirements. The value is eight times lower
than the acute toxic dose.

76
 Iron (Fe)

• SCF (1993) evaluated iron mainly to be a deficiency problem.

• WHO (2022) proposed that no health-based guideline value be set for
iron in drinking water.
• The recommended intake is 10-15 mg/day (Oskarsson and Sandström,
1995).
• Iron is an essential trace metal (JECFA, 1983). Iron problems are usually
related to deficiency rather than toxicity. Iron deficiency is generally
acknowledged to be the single most common nutritional deficiency in
both developing and developed countries (Oskarsson and Sandström,
1995). Certain iron salts, mainly ferrous sulfate and ferrous succinate,

Fe
are frequently used for the treatment and prevention of iron deficiency
in humans (Beliles, 1994). Under normal conditions, only about 10% of
the iron is actually absorbed (Tenenbein and Huang, 2022). 10-20 mg/kg
elemental iron may produce gastrointestinal symptoms that manifest as
nausea vomiting, diarrhea and abdominal pain.
• Iron supplementation of more than 30 mg/day could be associated with
iron accumulation indicators in older adults (Fleming et al., 2002).
• The Belgian Royal Decree of 30 May 2021 relating to the placing on the
market of nutrients and foodstuffs to which nutrients have been added
sets the maximum authorised intake via food supplements at 45 mg/day.
• In 2006, the EFSA NDA was unable to establish a tolerable upper intake
level as the data available were insufficient. The risk of adverse effects
from current dietary iron intakes, including fortified foods in some
countries but excluding supplements, was considered to be low for the
population as a whole, except those homozygous for hereditary haemo-
chromatosis. Mean dietary iron intake across the EU was in the range
of 10-22 mg/person/day and the 97.5th percentile ranged from 16 to
72 mg/person/day (EFSA, 2006).
• The EVM (2003) did not consider there to be sufficient data to derive
a safe upper level of iron intake, but they suggested that a supplemen-
tal intake of 0.28 mg/kg bw/day (17 mg/day) would not be expected to
produce adverse effects in the majority of people. This is based on data
showing that doses between 50 and 220 mg/day cause effects in humans,

77
 Metals and alloys used in food contact materials and articles

and using the lower end of this range and an uncertainty factor of 3 to
extrapolate from a LOAEL to a NOAEL. No factor for interspecies vari-
ation was required and, as the data had been collected in large numbers
of people, it was not deemed necessary to use an uncertainty factor for
inter-individual variation.
• ICH Q3D(R1): Iron is one of the elemental impurities for which PDEs
have not been established due to their low inherent toxicity.

Conclusions and recommendations

Fe

the SRL for iron of 40 mg/kg food or food simulant is reasonably achievable

Since no toxicologically derived upper limit could be set, it was decided that
an SRL for iron should be set at ALARA level. Such an approach ensures
that the manufacturer applies measures to prevent and reduce the release
of iron from FCM and articles as far as possible.
Data provided by industry and member states show that an SRL of 40 mg/kg
is reasonably achievable at present.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Beliles RP (1994). The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial
hygiene and toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc; 1994.
Arrêté royal concernant la mise dans la commerce de nutriments et de denrées alimen-
taires auxquelles des nutriments ont été ajoutés, 30 mai 2021 [Belgian Royal Decree of
30 May 2021 relating to the placing on the market of nutrients and food products with
added nutrients]. Belgian Official Journal of 11 June 2021 [available (in Dutch and French)
at https://www.health.belgium.be/fr/arrete-royal-nutriments-du-30-mai-2021, accessed
26 July 2023].
Bolle F, Brian W, Petit D, et al. Tea brewed in traditional metallic teapots as a significant
source of lead, nickel and other chemical elements. Food Addit Contam Part A Chem Anal
Control Expo Risk Assess 2011;28(9):1287-93. https://doi.org/10.1080/19440049.2011.580010.

78
 Iron (Fe)

EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
8546-fb176a685e13, accessed 17 Nov 2022].
European Parliament. Regulation (EC) No 1925/2006 of the European Parliament and of
the Council of 20 December 2006 on the addition of vitamins and minerals and of certain
other substances to foods. Official Journal of the European Union 2006;49:26-38.
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
Fleming DJ, Tucker KL, Jaques PF, et al. Dietary factors associated with the risk of high iron
stores in the elderly Framingham heart study cohort. Am J Clin Nutr 2002;76(6):1375-84.
ICH. Guideline for elemental impurities Q3D(R1). March 2019 [available at https://database.
ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_Guideline_2019_0322.pdf,

Fe
accessed 17 Nov 2022].
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 696. 1983 [available at https://apps.who.int/iris/handle/10665/39165, accessed
17 Nov 2022].
Kuligowski J, Halperin KM. Stainless steel cookware as a significant source of nickel, chro-
mium, and iron. Arch Environ Contam Toxicol 1992;23(2):211-15. https://doi.org/10.1007/
BF00212277.
Oskarsson A, Sandström B. A Nordic project – Risk evaluation of essential trace elements:
essential versus toxic levels of intake. Analyst 1995 120(3):911-12. https://doi.org/10.1039/
an9952000911.
SCF. Nutrient and Energy Intakes for the European Community. Reports of the Scien-
tific Committee for Food. 1993 [available at https://food.ec.europa.eu/system/files/2020-12/
sci-com_scf_out89.pdf, accessed 17 Nov 2022].
Tenenbein and Huang. Iron. In: Nordberg GF, Costa M, editors. Handbook on the toxicol-
ogy of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press; 2022.
https://doi.org/10.1016/B978-0-12-822946-0.00016-7.
UK Statutory Instrument No 141. The Bread and Flour Regulations. 1998 [available at
https://www.legislation.gov.uk/uksi/1998/141/made, accessed 24 Nov 2022].
WHO IPCS. Iron. Food Additives Series 18. 1983 [available at https://inchem.org/
documents/jecfa/jecmono/v18je18.htm, accessed 17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

79
 Magnesium (Mg)

Magnesium is an alkaline earth metal. It is the eighth

most abundant element in the Earth’s crust and the
third most common metal after aluminium and iron.
It is also the third most important component of salts
dissolved in seawater. Magnesium is a metal that has
few useful mechanical characteristics but is very light

Mg
(one-third lighter than aluminium), is silvery-white
in colour and tarnishes slightly on exposure to air.

Sources and levels of intake

Magnesium is widely used in medicine and pharmacology. It plays a very
important role in the human diet. Many disorders can result from lack of
magnesium: depression and anxiety, diabetes, muscle spasms, cramps, car-
diovascular disorders, high blood pressure and osteoporosis. It plays an
active role in inter-neuronal data transmission (Giannini, 1997; Giannini
et al., 2000).
Excess consumption is naturally eliminated, although intake of large quan-
tities of magnesium can cause diarrhoea. Magnesium is effectively filtered
by the kidneys in adults, but poisoning by excessive magnesium can occur
in children and in cases of renal insufficiency (Kontani et al., 2005).
Magnesium hydroxide Mg(OH)2, which is obtained by a reaction between
sodium hydroxide and magnesium salt, is used in medicine as an antacid,
as a laxative (milk of magnesia) and also in sugar refining.
Seafood (apart from winkles) contains 410 mg/100 g, and there is no
doubt that this is the food source richest in magnesium, followed by
molasses (197-242 mg/100 g), cocoa (150-400 mg/100 g) and whole grains
(100-150 mg/100 g). However, the polysaccharides and phytic acids that

81
 Metals and alloys used in food contact materials and articles

the latter contain impede magnesium absorption, especially in the case of

yeasted wholemeal bread. Spinach contains between 50 and 100 mg/100 g,
but it also contains oxalic acid that can inhibit magnesium assimilation.
Fish, offal and bolted cereals contain between 25 and 50 mg/100 g of mag-
nesium. A few other foodstuffs also contain magnesium, e.g. greens, buck-
wheat, broad beans, almonds, nigari (magnesium chloride) and bananas.
ANSES (2011) estimated mean daily intake at 304 mg/person/day in
adults and 227 mg/person/day in children. The highest concentrations in
the French Total Diet Study were measured in tofu (1 340 mg/kg), choc-
olate (1 143 mg/kg), molluscs and crustaceans (811 mg/kg) and cookies
(514 mg/kg).
Mg

Metallic food contact materials

Magnesium is mainly used in aluminium-magnesium alloys. It is also used
in the iron and steel industry to eliminate sulfur. It can be used in the man-
ufacturing of spheroidal graphite cast iron, in which the graphite takes the
form of nodules (spheroids) or cast iron (iron and steel industry).
Magnesium is widely used in aluminium-based alloys for permanent set
yielding, facilitating the manufacturing of profiles or beverage cans, which
consume large quantities of the metal (Luo and Powell, 2001).

Other food contact materials

No information available.

Release
No information available.

Safety aspects
• The SCF (2001) established a tolerable upper limit of 250 mg Mg per day
for readily dissociable magnesium salts and compounds like MgO in

82
 Magnesium (Mg)

nutritional supplements and water, or added to food and beverages. This

upper limit does not include Mg normally present in foods and beverages.
• Magnesium is used in the production of many alloys, particularly alumin-
ium alloys. It may constitute 11% of some alloys. The SCF (2001) and AFSSA
(2001) recommended that daily intake should not exceed 700 mg/day. The
Belgian Royal Decree of 30 May 2021 relating to the placing on the market
of nutrients and food products with added nutrients set the maximum
authorised intake via food supplements at 450 mg/day.
• The EVM (2003) assessed magnesium and considered there to be insuf-
ficient data to derive a safe upper level. On the basis of the available data
from one study showing only mild reversible diarrhoea in a small percent-
age of people supplementing magnesium at around 400 mg/person/day,

Mg
this level of magnesium supplementation was considered to be without
significant adverse effects. This corresponds to 6.7 mg/kg bw/day for a
60 kg adult.

Conclusions and recommendations

deriving an SRL for magnesium was unnecessary

With regard to the safety aspects mentioned above, it can be assumed that
release of magnesium from FCM made from metals and alloys at a level
where adverse effects occur is not likely. Therefore, it was concluded that
deriving an SRL was unnecessary.

References
Agence française de sécurité sanitaire des aliments (AFSSA). Apports nutritionnels con-
seillés pour la population française [Recommended dietary allowances for the French pop-
ulation]. 3rd edition. Paris : Tec et Doc Lavoisier ;2001.
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Arrêté royal concernant la mise dans la commerce de nutriments et de denrées alimentaires
auxquelles des nutriments ont été ajoutés, 30 mai 2021 [Belgian Royal Decree of 30 May 2021
relating to the placing on the market of nutrients and food products with added nutrients].

83
 Metals and alloys used in food contact materials and articles

Belgian Official Journal of 11 June 2021 [available (in Dutch and French) at https://www.
health.belgium.be/sites/default/files/uploads/fields/fpshealth_theme_file/2021_05_30_ar_
nutriments_kb_nutrienten_mb_bs_11_06_2021.pdf, accessed 24 Nov 2022].
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
Giannini AJ. Drugs of Abuse. 2nd Edition. Los Angeles: Practice Management Informa-
tion Corp; 1997.
Giannini AJ, Nakoneczie AM, Melemis SM, et al. Magnesium oxide augmentation of
verapamil maintenance therapy in mania. Psychiatry Res 2000;93(1):83-7. https://doi.
org/10.1016/s0165-1781(99)00116-x.
Kontani M, Hara A, Ohta S, et al. Hypermagnesemia induced by massive cathartic ingestion
in an elderly woman without pre-existing renal dysfunction. Intern Med 2005;44(5):448-
52. https://doi.org/10.2169/internalmedicine.44.448.
Luo AA, Powell BR. Tensile and Compressive Creep of Magnesium-Aluminium-Calcium
Mg

Based Alloys. In: Hyne J, editor. Magnesium Technology TMS, Materials Park, OH; 2001:
137-44.
SCF. Opinion of the SCF on the tolerable upper intake level of magnesium. SCF/CS/NUT/
UPPLEV/54 Final 11 October 2001 [available at https://ec.europa.eu/food/fs/sc/scf/out105_
en.pdf, accessed 21 Nov 2022].

84
 Manganese (Mn)

Manganese is an essential element as a micronutrient

involved in different enzymatic activities
(carbohydrate and lipid metabolism, bone formation,
healing processes, antioxidant protection, etc.). It is
widely distributed in the environment, comprising
approximately 0.1% of the Earth’s crust (Lucchini et
al., 2022). About 90% of total manganese production
is used in steel manufacture as a deoxidising
and desulfurising additive and as an alloying

Mn
constituent (Lucchini et al., 2022). Manganese exists
in two common oxidation states, as manganese
(II) and manganese (IV) (Florence et al., 1980).

Sources and levels of intake

Manganese is present in most foodstuffs. The main contributors of man-
ganese to the diet are cereals (10-30 mg/kg) as well as vegetables and fruits
(0.5-5 mg/kg) (Beliles, 1994). Nuts may also have a high content of manga-
nese. In some countries, manganese has replaced organic lead as an addi-
tive in petrol (Hoekman and Broch, 2016). This may result in increasing
concentrations of manganese in the environment and in foodstuffs.
The average intake is 2-3 mg/day (SCF, 1993). The UK Total Diet Study
reported that the highest total mean and 97.5th percentile exposures were in
the 1.5 to 3 year age class and were 160 μg/kg bw/day and 270 μg/kg bw/day,
respectively. The highest contributing food group to total mean exposure
was ‘non-alcoholic beverages’, with a mean exposure of 43 μg/kg bw/day
(FSA, 2014).

85
 Metals and alloys used in food contact materials and articles

In the French Total Diet Study (ANSES, 2011), the highest manganese
concentrations were measured in dry fruits and oil seeds (11.9 mg/kg),
chocolate (8.87 mg/kg) and bread and bakery products (7.19 mg/kg). The
main contributors to manganese exposure were bread (29%) and bakery
products (20%). It was established that the manganese mean exposures
were 2.16 mg/day for adults and 1.46 mg/day for children. Considering
the 95th percentile, the manganese mean exposures were 3.55 mg/day and
2.56 mg/day for adults and children, respectively.
The NDA (EFSA, 2013) proposed an AI of 3 mg/day for adults, including
pregnant and lactating women (equal to the mean intake in the EU). For
infants aged from 7 to 11 months, an AI of 0.02-0.5 mg/day was proposed,
which reflects the wide range of manganese intakes that appear to be ade-
quate for this age group.
In the Infant Total Diet Study (iTDS) (ANSES, 2016) focusing on the 0 to
3-year-old population, the highest manganese concentrations were meas-
Mn

ured in sweet and salty biscuits (6.26 mg/kg), bread and bakery products
(5.17 mg/kg) and pastry (3.64 mg/kg). For children between 1 and 4 months,
the main contributors to manganese exposures were first infant formulae
(74%) and infant cereals (14%). Between 5 and 6 months, the main con-
tributors were follow-on formulae (21%) and infant cereals (15%). Between
7 and 12 months, the main contributors were jarred meat/vegetables and
fish/vegetables (16%), infant cereals (13%) and fruits (11%). Between 13 and 36
months, the main contributors were vegetables (14%), fruits (12%) and pasta
(10%). It was estimated that the manganese mean exposures varied from
0.126 to 0.653 mg/day according to age group. Considering the 90th per-
centile, the manganese mean exposures varied from 0.348 to 1.26 mg/day
according to age group.

Metallic food contact materials

Manganese is used in steel and other alloys (Lucchini et al., 2022).

86
 Manganese (Mn)

Other food contact materials

Manganese is used in the manufacture of glass, for metal cleaning, tanning
and bleaching (Lucchini et al., 2022). It is also used in pigments, glazes and
other products.

Release
Release of manganese from six different grades of stainless steel contain-
ing 0.21-2.0 weight % manganese was examined in drinking water and in
waters with 500 mg/L chloride or 3 mg/L free chlorine. The release of man-
ganese was below 0.002 mg/L in all tests (Lewus et al., 1998).
Release of manganese from a range of seven stainless steel grades used as
FCM was examined (food simulant 5 g/L citric acid, pH 2.4 and 1 cm2 in
2 mL test medium) after exposure for 2 hours at 70°C followed by 24 and
238 hours at 40°C. Manganese release for all stainless steel grades and test

Mn
conditions investigated were below the applicable SRL (1.8 mg/kg) and did
not exceed 0.4 µg/cm2 (Hedberg et al., 2014). The study was extended using
as-received and pre-passivated 6 cm2 specimens and three different sim-
ulants; artificial tap water, 5 g/L citric acid and 5 g/L citric acid + 0.5 M
NaCl (conditions: 2 hours at 70°C followed by 10 days at 40°C). Manganese
release was close to the detection limits for all grades in artificial tap water.
Higher release was observed in citric acid, but did not exceed the SRL and
release was noted to reduce with time (Mazinanian et al., 2016).

Safety aspects
• JECFA has not evaluated manganese.
• The SCF (1993) recommends 1-10 mg/day as the acceptable intake range.
• The SCF (1996) recommends a maximum limit of 0.5 mg/L for manganese
in natural mineral waters.
• In its 2001 recommendation, AFSSA (France) set a safety limit of
10 mg/day. In the iTDS, a security upper limit of 2 mg/day (fixed by the

87
 Metals and alloys used in food contact materials and articles

institute of medicine) was retained by ANSES (2016) for 1 to 3-year-old

infants.
• The Belgian Royal Decree of 30 May 2021 sets the maximum authorised
intake via food supplements at 1 mg/day.
• WHO (2003) derived a limit of 0.06 mg/kg bw/day (3.6 mg/day) within
the drinking-water guidelines. This limit was derived from the average
nutritional intake of manganese for an adult of 11 mg/day and an uncer-
tainty factor of 3 (for the possible higher bioavailability of manganese
in water) and resulted in a guideline value of 0.4 mg/L. In 2022, a provi-
sional guideline value was set at 0.08 mg/L (WHO, 2022).
• Both the SCF (2000) and EFSA (2006) concluded that an upper level
of manganese cannot be set due to the limitations of the human data
and the non-availability of NOAELs for critical endpoints from animal
studies, thereby producing a considerable degree of uncertainty. To date,
the LOAELs following oral administration observed are 0.28 mg/kg
Mn

bw/day in growing male rats and 0.36 mg/kg bw/day in adult female rats
(SCF, 2000; EFSA, 2006).
• Manganese is an essential trace element that plays a role in bone min-
eralisation, protein and energy metabolism, metabolic regulation, cel-
lular protection from damaging free radicals, and the formation of
glycosaminoglycans (ATSDR, 2012). Although manganese is an essential
nutrient, exposure to high levels via inhalation or ingestion may cause
some adverse health effects (ATSDR, 2012). Excess manganese affects
the central nervous system and neurological effects have been observed
in cases of occupational exposure. No problems have been reported in
connection with dietary intake of manganese, since it is considered one
of the least toxic metals. Consistent with its role as an essential element,
manganese and its inorganic compounds have a relatively low order of
acute toxicity (Beliles, 1994). However, absorption is increased in individ-
uals with iron deficiency (Beliles, 1994). In humans, the degree of manga-
nese absorption from the gastrointestinal system is generally low, in the
order of 3% (Beliles, 1994).
• The EVM (2003) could not derive an upper intake limit. However, guid-
ance levels where no adverse effects are expected were derived using

88
 Manganese (Mn)

two retrospective studies. In these studies, the cohorts were exposed to

either two or three different concentrations, respectively, of manganese
in drinking water. The study using three different manganese concentra-
tions found significant neurological effects and symptoms in the highest
exposure group. Based on the NOAEL for these effects, the EVM derived
a guidance level for older people of 0.15 mg/kg bw/day (9 mg/day). No sig-
nificant effects were observed at either concentration in the second study.
Hence, the EVM derived a guidance level for the general population of
0.2 mg/kg bw/day (12 mg/day) using the higher concentration.
• ICH Q3D(R1): manganese is one of the elemental impurities for which
PDEs have not been established due to their low inherent toxicity.
• In the ANSES opinion (2018) related to the maximal safety value of man-
ganese in drinking water, the TRV of 55 μg/kg bw/day established by the
national public health institute of Québec was selected (Valcke et al.,
2018). This TRV was derived using a LOAEL of 25 mg/kg bw/day based on

Mn
neurological effects observed in rats during development after postnatal
exposure (Kern et al., 2010 and 2011, Beaudin et al., 2013 and 2015).

Conclusions and recommendations

the SRL for manganese is set at 0.55 mg/kg food or food simulant

The SRL is based on the TRV of 55 μg/kg bw/day established by the national
public health institute of Québec, and since oral intake data from multi-
ple European countries are not available, an allowance of 20% for FCM is
applied. Since the endpoint for the calculation of this reference value was
based on neurological effects observed during development after postnatal
exposure, the recommended SRL is calculated considering toddlers as the
target population. Based on the food consumption values adopted by EFSA
(2016), a toddler consumes 20 g of foodstuffs (other than drinks and food
specially intended for infants and toddlers) per kg bw/day. Consequently,
the SRL for manganese is set at 0.55 mg/kg.
Particularly for materials and articles intended for contact with milk, milk
products and other non-alcoholic drinks as well as any food especially

89
 Metals and alloys used in food contact materials and articles

intended for infants and toddlers, the most conservative consumption of

150 mg/kg bw/day should be used and an SRL of 0.07 mg/kg food applies.

References
Agence française de sécurité sanitaire des aliments (AFSSA). Apports nutritionnels con-
seillés pour la population Française [Recommended dietary allowances for the French
population]. 3rd edition. Paris : Tec et Doc Lavoisier ; 2001.
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
ANSES. Étude de l’alimentation totale infantile – Tome 2 – Partie 2 Composés inor-
ganiques [Infant Total Diet Study (iTDS) – Volume 2 – Part 2 Inorganic compounds].
September 2016 [available at https://www.anses.fr/en/content/infant-total-diet-study-itds,
accessed 20 Sep 2021].
ANSES. Avis relatif à la détermination d’une valeur sanitaire maximale admissible pour le
manganèse dans l’eau destinée à la consommation humaine [Opinion related to the deter-
Mn

mination of manganese maximal safety value allowed in drinking water]. April 2018 [avail-
able at https://www.anses.fr/fr/system/files/EAUX2016SA0203.pdf, accessed 21 Nov 2022].
ATSDR. Toxicological profile for manganese. US Department of Health and Human
Services. 2012 [available at https://www.atsdr.cdc.gov/ToxProfiles/tp151.pdf, accessed
17 Nov 2022].
Arrêté royal concernant la mise dans le commerce de nutriments et de denrées alimen-
taires auxquelles des nutriments ont été ajoutés, 30 mai 2021 [Belgian Royal Decree relat-
ing to the placing on the market of nutrients and food products with added nutrients].
Belgian Official Journal of 11 June 2021 [available (in Dutch and French) at https://www.
health.belgium.be/sites/default/files/uploads/fields/fpshealth_theme_file/2021_05_30_ar_
nutriments_kb_nutrienten_mb_bs_11_06_2021.pdf, accessed 24 Nov 2022].
Beaudin SA, Nisam S, Smith DR. Early life versus lifelong oral manganese exposure differ-
ently impairs skilled forelimb performance in adult rats. Neurotoxicol Teratol 2013;38:36-
45. https://doi.org/10.1016/j.ntt.2013.04.004.
Beaudin SA, Strupp BJ, Lasley SM, et al. Oral methylphenidate alleviates the fine motor
dysfunction caused by chronic postnatal manganese exposure in adult rats. Toxicol Sci
2015;144(2):318-27. https://doi.org/10.1093/toxsci/kfv007.
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
8546-fb176a685e13, accessed 17 Nov 2022].

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 Manganese (Mn)

EFSA. Scientific Opinion on Dietary Reference Values for manganese. NDA. EFSA Journal
2013;11(11):3419. https://doi.org/10.2903/j.efsa.2013.3419.
EFSA. Recent developments in the risk assessment of chemicals in food and their poten-
tial impact on the safety assessment of substances used in food contact materials. EFSA
Panel on Food Contact Materials, Enzymes, Flavourings and Processing Aids (CEF). EFSA
Journal 2016;14(1):4357. https://doi.org/10.2903/j.efsa.2016.4357.
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
Florence TM, Batley GE, Benes P. Chemical speciation in natural waters. Crit Rev Anal
Chem 1980;9:3:219-96. https://doi.org/10.1080/10408348008542721.
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/sites/default/files/media/
document/measurement-of-the-concentrations-of-metals-and-other-elements-from-the-
2014-uk-total-diet-study.pdf, accessed 17 Nov 2022].
Hedberg Y, Mazinanian N, Wallinder IO. Compliance tests of stainless steel as a food
contact material using the CoE test guideline. KTH Royal Institute of Technology. Decem-
ber 2014 [available at http://bit.ly/1USTJjn, accessed 17 Nov 2022].

Mn
Hoekman SK, Broch A. MMT Effects on Gasoline Vehicles: A Literature Review. SAE Int
J Fuels Lubr 2016;9(1)322-43 [available at https://www.jstor.org/stable/26273472, accessed
21 Nov 2022].
ICH. Guideline for elemental impurities Q3D(R1). March 2019 [available at https://database.
ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_Guideline_2019_0322.pdf,
accessed 17 Nov 2022].
Kern CH, Stanwood GD, Smith DR. Pre-weaning manganese exposure causes hyperactiv-
ity, disinhibition, and spatial learning and memory deficits associated with altered dopa-
mine receptor and transporter levels. Synapse 2010;64(5):363-78. https://doi.org/10.1002/
syn.20736.
Kern CH, Smith DR. Pre-weaning Mn exposure leads to prolonged astrocyte activation
and lasting effects on the dopaminergic system in adult male rats. Synapse 2011 ;65(6) :532-
44. https://doi.org/10.1002/syn.20873.
Lewus MO, Hambleton R, Dulieu D, et al. Behavior of ferritic, austenitic and duplex stain-
less steels with different surface finishes in tests for metal release into potable waters based
upon the procedure BS7766:1994. Stainless Steel Conference Proceedings. 1998.
Lucchini RG, Aschner M and Kim Y. Manganese. In: Nordberg GF, Costa M, editors.
Handbook on the toxicology of metals. Volume II, Specific metals. 5th edition. Amster-
dam: Academic Press; 2022. https://doi.org/10.1016/B978-0-12-822946-0.00019-2.
Mazinanian N, Herting G, Odnevall Wallinder I, et al. Metal Release and Corrosion
Resistance of Different Stainless Steel Grades in Simulated Food Contact, Corrosion
2016;72(6):775-90. https://doi.org/10.5006/2057.

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 Metals and alloys used in food contact materials and articles

SCF. Nutrient and Energy Intakes for the European Community. Reports of the Scien-
tific Committee for Food. 1993 [available at https://food.ec.europa.eu/system/files/2020-12/
sci-com_scf_out89.pdf, accessed 17 Nov 2022].
SCF. Opinion on arsenic, barium, fluoride, boron and manganese in natural mineral waters.
December 1996 [available at https://food.ec.europa.eu/system/files/2020-12/sci-com_scf_7_
out09_en.pdf, accessed 21 Nov 2022].
SCF. Opinion of the SCF on the tolerable upper intake level of manganese. SCF/CS/NUT/
UPPLEV/21 November 2000.
Valcke M, Bourgault MH, Haddad S, et al. Deriving a drinking water guideline for a
non-carcinogenic contaminant: the case of manganese. Int J Environ Res Public Health
2018;15(6)1293. https://doi.org/10.3390/ijerph15061293.
WHO. Manganese in drinking-water. Background document for development of WHO
Guidelines for Drinking-water Quality. WHO/SDE/WSH/03.04/104; 2003 [available at
https://apps.who.int/iris/handle/10665/75376, accessed 17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].
Mn

92
 Molybdenum (Mo)

Molybdenum does not occur naturally as a free

metal on Earth; it is found only in various oxidation
states in minerals. In its elemental state, it is a hard
silvery-grey metal with a density of 10.2 g/cm3 (at room
temperature). Molybdenum is a trace element essential
for nearly all organisms and forms the catalytic centre
of a large variety of enzymes such as nitrogenase,
nitrate reductases, sulfite oxidase and xanthine
oxidoreductases (Schwarz et al., 2009). It is found
ubiquitously in animals and plants. The human body
contains approximately 9 mg of Mo (Rumble, 2022).

Mo
Sources and levels of intake
Some of the main natural sources of molybdenum are liver, peas, beans,
spinach, wheat germ (Emsley, 2001), and dark leafy greens such as spinach
and kale.
EFSA (2009) estimated oral intake for adults from food at up to
500 μg/day, and for children aged 1-3 years old, up to 89 μg/day. The 2006
UK Total Diet Study estimated the mean and high-level intake for adults
at 96.6-98.4 μg/person/day and 181.8-184.8 μg/person/day, as calculated
using a bw of 60 kg and from the mean (1.61-1.64 µg/kg bw/day) and high
(3.03-3.08 µg/kg bw/day) level exposures, respectively (Rose et al., 2010).
ANSES (2011) estimated mean daily intake at 93.9 μg/person/day in adults
and the 95th percentile at 155 mg/person/day.

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 Metals and alloys used in food contact materials and articles

Metallic food contact materials

Molybdenum is used as an alloying addition in stainless steels that increases
resistance to both uniform and local corrosion, such as pitting and crack-
ing. The use of molybdenum-containing steel may be required where
contact is expected with highly corrosive liquids, like fruit juice, vinegar,
wine and carbonated beverages (Mason, 1948). The most commonly used
molybdenum-containing material for food contact applications is stainless
steel 316 (2-2.5% Mo in an iron alloy) and its derivatives, but steels with
higher or lower molybdenum percentages are also used (Euro Inox, 2006).
Hastelloy C-276 (a highly corrosion-resistant Ni-Cr-Mo-Fe alloy) has been
used for coffee flash dryers. Inconel and Hastelloy B & C have been used
for the following food applications: fruit juice and syrups, pectin, gela-
tine, salad dressings, vinegar, monosodium glutamate, baker’s yeast and
carbonated beverages (Mason, 1948); stainless steel grade 316 (2-2.5% Mo)
articles are also used for these food contact applications, as they are highly
resistant and do not corrode, even at high temperatures. Molybdenum is
also an alloying element in nickel-based alloys used in FCM.
Mo

Other food contact materials

Molybdenum oxides are a constituent of pigments commonly used in
ceramics used for food contact.

Release
Stainless steel grade 316L exposed to 5 g/L citric acid for 2 hours at 70°C
followed by 10 days at 40°C released 0.02 μg/cm2 of molybdenum (i.e.
0.012 mg/6 dm2) (Hedberg et al., 2014). Stainless steel grade 316L exposed
to 1% lactic acid or 0.01% HCl for 1 week at 37°C released 0.2 µg/cm2 and
0.06 µg/cm2 of molybdenum, respectively (Okazaki and Gotoh, 2005). The
pH of 1% lactic acid and 0.01% HCl solutions is comparable to that of 5 g/L
citric acid (i.e. pH 2.4).

94
 Molybdenum (Mo)

Safety aspects
• The SCF (2000) and EFSA (2006) laid down an upper limit for molyb-
denum of 0.6 mg/day. This limit was based on an uncertainty factor of
100 using a NOAEL of 0.9 mg/kg bw/day from a 9-week study in rats
(incorporating an uncertainty factor of 10 for the additive effect of Cu
deficiency in metabolism and an uncertainty factor of 10 for the effects on
human reproduction). Furthermore, for children aged 1-3 years an upper
limit of 0.1 mg/day was extrapolated from the adult upper limit due to
adverse effects on growth seen in young rats. EFSA (2009) confirmed
these derived upper limits in an opinion of the ANS Panel.
• The EVM assessed molybdenum and determined that there was insuffi-
cient data to derive a safe upper level (EVM, 2003). One study reported
that intakes of 1 mg/person/day and above could be associated with
gout-like symptoms. However, the intake of molybdenum in the UK diet
(maximum 0.23 mg/person/day) was not expected to present a risk.
• Molybdenum is used in the synthesis of pharmaceutical substances
(Mo combinations such as Bi-Mo, Fe-Mo, molybdenum oxide and

Mo
Mo-complexes, are being used as catalysts in organic synthesis). It is cat-
egorised in Class 3 of the ICH Q3D(R1) Guideline, metals of relatively
low toxicity, with an oral PDE of 3 400 μg Mo/day for a 50 kg individual,
based on a NOAEL of 17 mg Mo/kg/day from a 90-day toxicity study in
the rat with dietary sodium molybdate dehydrate bw of 50 kg and a safety
factor of 250 (Murray et al., 2013).

Conclusions and recommendations

the SRL for molybdenum is set at 0.12 mg/kg food or food simulant

The SRL is calculated from the upper limit derived by EFSA (2006, 2009) of
0.6 mg/day, which agrees with the TDI (oral exposure) of 10 µg/kg bw/day
reported by RIVM (2001).
Intake data from multiple European countries was provided by EFSA
(2009). However, the data used in 2009 had been taken from earlier SCF
opinions and contained data originating from the 1980s.

95
 Metals and alloys used in food contact materials and articles

Since newer intake data were only available from two European countries,
the default allowance of 20% for exposure to FCM and articles made from
metals and alloys was applied to the upper limit of 0.6 mg/day. Conse-
quently, assuming that a person of 60 kg bw consumes 1 kg of foodstuffs
per day that is packaged and/or prepared with FCM made from metals and
alloys, the SRL for molybdenum is set at 0.12 mg/kg.
Children are not considered as a vulnerable sub-population because of the
negligible exposure of children to FCM and articles containing molybde-
num (Foster et al., 2010).

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
Mo

8546-fb176a685e13, accessed 17 Nov 2022].

EFSA. Scientific Opinion on potassium molybdate as a source of molybdenum added
for nutritional purposes to food supplements. EFSA Panel on Food Additives and Nutri-
ent Sources added to Food (ANS). EFSA Journal 2009;7(6):1136. https://doi.org/10.2903/j.
efsa.2009.1136.
Emsley J. Nature’s building blocks: an A-Z guide to the elements. Oxford: Oxford Univer-
sity Press; 2001: 262-6.
Euro Inox. Stainless Steel in the Food and Beverage Industry. Materials and Applica-
tions Series, Volume 7, 1st Edition. 2006 [available at https://www.worldstainless.org/
Files/issf/non-image-files/PDF/Euro_Inox/StSt_in_FoodandBeverage_EN.pdf, accessed
21 Nov 2022].
Foster E, Mathers JC, Adamson AJ. Packaged food intake by British children aged 0 to 6
years. Food Addit Contam Part A Chem Anal Control Expo Risk Assess 2010;27(3):380-8.
https://doi.org/10.1080/19440040903367161.
Hedberg Y, Mazinanian N, Wallinder IO. Compliance tests of stainless steel as a food
contact material using the CoE test guideline. KTH Royal Institute of Technology. Decem-
ber 2014 [available at http://bit.ly/1USTJjn, accessed 17 Nov 2022].

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 Molybdenum (Mo)

ICH. Guideline for elemental impurities Q3D(R1). March 2019 [available at https://database.
ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_Guideline_2019_0322.pdf,
accessed 17 Nov 2022].
Mason JF. The Resistance of Alloys to Corrosion During the Processing of Some Foods.
Corrosion 1948;4(7):305-20. https://doi.org/10.5006/0010-9312-4.7.305.
Murray FJ, Sullivan FM, Tiwary AK, et al. 90-Day subchronic toxicity study of sodium
molybdate dihydrate in rats. Regul Toxicol Pharmacol 2013;70(3):579-88. http://dx.doi.
org/10.1016/j.yrtph.2013.09.003.
Okazaki Y, Gotoh E. Comparison of metal release from various metallic biomaterials in
vitro. Biomaterials 2005;26(1):11-21. https://doi.org/10.1016/j.biomaterials.2004.02.005.
RIVM. Re-evaluation of human-toxicological maximum permissible risk levels. RIVM
Report 711701 025. 2001 [available at https://www.rivm.nl/bibliotheek/rapporten/711701025.
pdf, accessed 17 Nov 2022].
Rose M, Baxter M, Brereton N, et al. Dietary exposure to metals and other elements in the
2006 UK Total Diet Study and some trends over the last 30 years. Food Addit Contam Part
A Chem Anal Control Expo Risk Assess 2010;27(10):1380-404. https://doi.org/10.1080/19440
049.2010.496794.
Rumble JR (ed.), “Elemental Composition of the Human (Male) Body” in: CRC Handbook
of Chemistry and Physics, 103rd edition (online version 2022), CRC Press/Taylor & Francis,
Boca Raton, FL.

Mo
SCF. Opinion of the SCF on the tolerable upper intake levels of molybdenum 2000 [avail-
able at https://ec.europa.eu/food/fs/sc/scf/out80h_en.pdf, accessed on 23 February 2023].
Schwarz G, Mendel RR, Ribbe MW. Molybdenum cofactors, enzymes and pathways.
Nature 2009;460(7257):839-47. https://doi.org/10.1038/nature08302.

97
 Nickel (Ni)

Nickel, combined with other elements, occurs

naturally in the Earth’s crust and is found in all
soils. It is the 24th most abundant element and,
in the environment, nickel is found primarily as
oxides or sulfides (ATSDR, 2005). There has been a
growing interest in the possible effects of nickel in
foodstuffs, i.e. a possible worsening of nickel-related
dermatitis in the nickel hypersensitive population.
Nickel is an essential micronutrient for higher plants
and some animal species, but there are no data
proving that it is essential for humans (EFSA, 2015).

Sources and levels of intake

In a monitoring program initiated in 1990 in Denmark, nickel was found

Ni
in small quantities in many foodstuffs (0.001-0.01 mg/kg) and in higher
concentrations in foodstuffs such as grains, nuts, cocoa products and seeds
(up to 0.8 mg/kg) (National Food Agency of Denmark, 1995). At FoodEx
level 1, high mean levels of Ni were reported for ‘Legumes, nuts and oil-
seeds’ (~ 2 mg/kg), certain types of chocolate (cocoa) products (3.8 mg/kg),
and ‘Cocoa beans and cocoa products’ (9.5 mg/kg) (EFSA, 2015).
In the diet it is found as complex bound Ni2+-ions. The UK Total Diet
Study (2006) estimated mean and high nickel intake levels for adults to be
0.09-0.1 mg/day (1.49-1.63 μg/kg bw/day) and 0.18 mg/day (3.01-3.08 μg/kg
bw/day), respectively (FSA, 2009). In the 2014 UK Total Diet Study (FSA,
2019) the highest total mean and 97.5th percentile nickel exposures were in
the 1.5 to 3 years age class and were 4.4-5.2 μg/kg bw/day and 7.1-8.1 μg/kg

99
 Metals and alloys used in food contact materials and articles

bw/day, respectively. For older children, adolescents and adults the 97.5th
percentile nickel exposures were in the range of 3.2-7.3 μg/kg bw/day.
ANSES (2011) estimated mean daily intake at 2.33 μg/kg bw/day in adults
and 3.83 μg/kg bw/day in children. In the Infant Total Diet Study (iTDS),
these mean exposures were used (ANSES, 2016). Exposure at the 95th per-
centile was 3.76 and 7.44 µg/kg bw/day for adults and children, respectively.
For these populations, nickel exceedance in food (naturally occurring in
food) was observed (Sirot et al., 2018).
EFSA (2015) estimated chronic dietary exposure to Ni combining food mean
occurrence data with food consumption data at the individual level. Mean
chronic dietary exposure to nickel across the different dietary surveys and
age classes ranged from 2.0 (minimum LB, ‘Elderly’) to 13.1 μg/kg bw/day
(maximum UB, ‘Toddlers’). The 95th percentile dietary exposure ranged
from 3.6 (minimum LB, ‘Elderly’) to 20.1 μg/kg bw/day (maximum UB,
‘Toddlers’). In the update of its risk assessment, EFSA (2020) established
that: the exposure ranged from 1.57 (minimum mean LB, ‘Elderly’) to
14.6 μg/kg bw/day (maximum mean UB, ‘Toddlers’); the 95th percentile
dietary exposure ranged from 3.55 (minimum LB, ‘Elderly’) to 24.8 μg/kg
bw/day (maximum UB, ‘Toddlers’). The highest exposure was found for
toddlers and other children.
Ni

Metallic food contact materials

In total, 79% of the worldwide production of nickel is used for the man-
ufacturing of alloys, 6% for plating and 11% for other uses (e.g. batteries)
(Nickel Institute, 2022). There are at least 3 000 different alloys contain-
ing nickel. The major use of nickel is in the production of high-quality,
corrosion-resistant alloys with iron, copper, aluminium, chromium, zinc
and molybdenum. Most nickel-containing FCM are stainless steels.
Nickel-containing stainless steels (see Chapter 2, Stainless steels) are
important FCM used for transport (e.g. in milk trucks), for processing
equipment (e.g. in the dairy and chocolate industry), in processing of fruit
such as apples, grapes, oranges and tomatoes, for containers such as wine
tanks, for brew kettles and beer kegs, for processing of dry foods such as
cereals, flour and sugar, for utensils such as blenders and bread-dough

100
 Nickel (Ni)

mixers, in slaughterhouses, in fish processing, for nearly all of the equip-

ment in professional kitchens such as restaurants and hospitals, for elec-
tric kettles, cookware and kitchen appliances of all kinds, for sinks, bowls,
knives, spoons and forks.
Other nickel-containing FCM include German silver (also known as nickel
silver and Maillechort), which is used for cutlery and as a base for silver-
ware, and nickel bronze (also known as dairy bronze and Thai bronze),
which is used for cutlery and dairy equipment (see Chapter 2, Alloys).
Nickel-plated items (electroplated) are less durable and less
corrosion-resistant than stainless steel and are therefore not commonly
used for articles in contact with food and drink. Electroless nickel coat-
ings (nickel/phosphorus alloy) containing 2-14% phosphorus are durable
and have found many applications in the food industry, in particular as a
protective coating for many different components which do not come into
direct contact with food. The preferred electroless nickel coating for most
applications in the food industry is the high phosphorus type containing
10-12% phosphorus. (Parkinson, 2001). For chromium-plated objects, the
materials are consecutively given a copper, nickel and then a chromium
layer. Kitchen utensils such as strainers and heating coils in electric kettles
may be nickel-plated. The latter are now rare; concealed (stainless steel)
heating coils make de-scaling of kettles much easier.

Ni
Other food contact materials
Nickelous oxide, NiO, is used in the production of enamel frits and ceramic
glazes, and in glass manufacture (Beliles, 1994). Basic nickel carbonate is
used in colouring ceramics and glazes (Beliles, 1994).

Release
A study comparing foods prepared in different stainless steel and glass pans
found a higher nickel content in the stainless steel-cooked foods. However,
the additional contribution from the stainless steel represented only a
minor fraction of the nickel content in the foods (Accominotti, 1998). In
a similar study, acidic foods such as rhubarb cooked in new stainless steel

101
 Metals and alloys used in food contact materials and articles

pans only showed significant pick-up of nickel during the first cooking
operation (Flint and Packirisamy, 1997). Using boiling 5% acetic acid as a
simulant for 5 minutes in stainless steel pans, nickel release ranged between
0.08 and 0.21 mg/kg (Kuligowski and Halperin, 1992). A survey of teapots
showed nickel release of between 1.2 mg/L and 35 mg/L using a citric acid
solution (1 g/L) as a simulant and a contact time of 30 minutes. (Bolle et al.,
2011). Release of nickel from a range of seven stainless steel grades used as
FCM was examined (food simulant 5 g/L citric acid, pH 2.4 and 1 cm2 in
2 mL test medium) after exposure for 2 hours at 70°C followed by 24 and
238 hours at 40°C. Nickel release for all stainless steel grades and test con-
ditions investigated was below the applicable SRL (1.4 mg/kg) and did not
exceed 0.06 µg/cm2 (Hedberg et al., 2014). The study was extended using
as-received and pre-passivated 6 cm2 specimens and three different simu-
lants; artificial tap water, 5 g/L citric acid and 5 g/L citric acid + 0.5 M NaCl
(conditions: 2 hours at 70°C followed by 10 days at 40°C). Nickel release
was close to the detection limits for all grades in artificial tap water. Higher
release was observed in citric acid, but did not exceed the SRL and release
was noted to reduce with time (Mazinanian et al., 2016).
For the years 2020 to 2023, RASFF shows 18 notifications for nickel release,
especially from bakeware (up to 19.76 ± 1.97 mg/L).
Ni

Safety aspects
• JECFA has not evaluated nickel.
• In 2008, AFSSA set a TDI of 22 μg/kg bw/day, based on a 2-generation
rat study.
• EFSA (2005) could not derive a tolerable upper intake level for nickel
in the evaluation of safety of fortified foods and food supplements due
to the absence of adequate dose-response data for dermal reactions in
nickel-sensitised subjects.
• EFSA (2015, updated in 2020) identified reproductive and developmen-
tal toxicity as the critical effect for the risk characterisation of chronic
oral exposure to Ni. They derived a TDI of 2.8 μg Ni/kg bw/day from a
BMDL10 of 0.28 mg Ni/kg bw/day as calculated from the dose-response

102
 Nickel (Ni)

analysis of the incidence of post-implantation foetal loss in rats, applying

the default uncertainty factor of 100 to allow for interspecies differences
and human variability.
• The BfR (Tietz et al., 2018) reported a refinement of the modelling per-
formed by EFSA (2015) using a nested data approach, which includes
litter effects and outlier treatment. The modelling procedure used was in
accordance with the EFSA opinion on BMD Modelling (EFSA, 2017). The
TDI of 11 µg/kg bw/day derived was in accordance with conclusions from
other studies.
• EFSA (2020) updated the previous Scientific Opinion, taking into account
new occurrence data, the updated BMD Guidance and any newly avail-
able scientific information. The critical effect for chronic exposure was
confirmed to be post-implantation loss and perinatal death of foetuses (as
used in the previous Opinions). A TDI of 13 μg Ni/kg bw/day was derived
from a BMDL10 of 1.3 mg Ni/kg bw/day, applying the default uncertainty
factor of 100 to account for interspecies differences and human variability.
• The absorption and retention of nickel in the gastrointestinal tract is influ-
enced by fasting and food intake. Food intake and gastric emptying are
of substantial significance for the bioavailability of nickel from aqueous
solutions. The absorption of free nickel ions released in the gastrointesti-
nal tract may be 40 times higher than that of complex bound nickel from

Ni
foodstuffs (Sunderman et al., 1989). The absorption of nickel from drink-
ing water is increased by fasting (Nielsen et al., 1999). It is believed that
5-15% of ingested nickel is absorbed from the gastrointestinal tract (Klein
and Costa, 2022). Nickel intake via foodstuffs does not cause hazards for
the majority of consumers. A subgroup of the population (approximately
10%, mainly women) has contact allergies to nickel. Sensitisation against
nickel is caused by exposure through skin or by inhalation (EFSA, 2015).
However, some patients with certain types of nickel dermatitis may get a
flare-up of eczema through oral ingestion of even small amounts of nickel,
e.g. from foodstuffs rich in nickel or foodstuffs or drinks contaminated
by nickel-containing materials (Veien, 1989; Veien and Menné, 1990).

103
 Metals and alloys used in food contact materials and articles

• WHO (2022) derived a guideline value for nickel in drinking water

of 0.07 mg/L and identified leaching from metals in contact with
drinking-water as its primary source.
• The EVM also assessed nickel and while they could not derive a safe
upper level, they determined that intakes of 0.0043 mg/kg bw/day would
not be expected to affect non-sensitised individuals (EVM, 2003). This
guidance is based on a LOAEL for increased perinatal mortality in a
multi-generation rat study of 1.3 mg/kg bw/day and using uncertainty
factors of 10 for interspecies variation, 10 for intraspecies variation and 3
for extrapolation of a LOAEL to a NOAEL.
• The COT (2008) considered that UK dietary exposures above the EVM
guidance level were unlikely to be of toxicological concern, though they
noted that nickel may exacerbate contact dermatitis/eczema in presen-
sitised individuals. The COT had previously concluded that pre-school
children who have the highest exposures are less likely than adults to be
sensitised and would therefore not be considered to be a sensitive sub-
group. In 2018, the COT concluded, based on acute and chronic effects,
that it is not possible to determine whether there is a risk of sensitisation
to nickel in infants and young children exposed to nickel through the
diet. The effect from indigestion of an acute exposure of nickel in sensi-
tised individuals could be a dermal reaction, which although unpleasant
Ni

is not life-threatening.
• According to ICH Q3D(R1), the oral nickel PDE is 220 µg/day.

Conclusions and recommendations

the SRL for nickel is set at 0.14 mg/kg food or food simulant

This SRL is derived from the EFSA TDI of 0.013 mg/kg bw/day. This con-
servative TDI is based on human data from nickel-sensitised individuals.
The default allowance of 20% for exposure through FCM and articles made
from metals and alloys was applied to the TDI. Assuming that a person of
60 kg bw consumes 1 kg of foodstuffs per day that is packaged and/or pre-
pared with FCM made from metals and alloys, the SRL is set at 0.14 mg/kg.

104
 Nickel (Ni)

Care has to be taken to ensure that nickel-plated and electroless nickel-plated

articles for direct contact with foodstuffs comply with the SRL for nickel.

References
Accominotti M, Bost M, Haudrechy P, et al. Contribution to chromium and nickel
enrichment during cooking of foods in stainless steel utensils. Contact Dermatitis
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de sécurité sanitaire des aliments relatif à la demande d’informations générales sur la tox-
icité du Nickel dans la chaîne alimentaire » [Opinion of 1 July 2008 on the application of
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anses.fr/fr/system/files/RCCP2007sa0245.pdf, accessed 23 February 2023].
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
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ANSES. Étude de l’alimentation totale infantile [Infant Total Diet Study (iTDS)]. 2016
[available at https://www.anses.fr/en/system/files/ERCA2010SA0317Ra.pdf, accessed
21 Nov 2022].
ATSDR. Toxicological profile for nickel. US Department of Health and Human Services.
2005 [available at https://www.atsdr.cdc.gov/toxprofiles/tp15.pdf, accessed 21 Nov 2022].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.

Ni
Bolle F, Brian W, Petit D, et al. Tea brewed in traditional metallic teapots as a significant
source of lead, nickel and other chemical elements. Food Addit Contam Part A Chem Anal
Control Expo Risk Assess 2011;28(9):1287-93. https://doi.org/10.1080/19440049.2011.580010.
COT. Statement on the 2006 UK Total Diet Study of Metals and Other Elements. Decem-
ber 2008 [available at https://cot.food.gov.uk/sites/default/files/cot/cotstatementtds200808.
pdf, accessed 21 Nov 2022].
COT. Statement on potential risks from nickel in the diet of infants aged 0 to 12 months
and children aged 1 to 5 years. February 2018 [available at https://cot.food.gov.uk/sites/
default/files/statementonpotentialrisksofnickel.pdf, accessed 21 Nov 2022].
EFSA. Tolerable Upper Intake Level of Nickel. NDA. EFSA Journal 2005;3(2):146. https://
doi.org/10.2903/j.efsa.2005.146.
EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
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EFSA. Scientific Opinion on the risks to public health related to the presence of nickel in
food and drinking water. CONTAM. EFSA Journal 2015;13(2):4002. https://doi.org/10.2903/j.
efsa.2015.4002.
EFSA. Update: use of the benchmark dose approach in risk assessment. EFSA Journal
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EFSA. Update of the risk assessment of nickel in food and drinking water. CONTAM.
EFSA Journal 2020;18(11):6268. https://doi.org/10.2903/j.efsa.2020.6268.
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/vitmin2003.pdf, accessed 17 Nov 2022].
Flint GN, Packirisamy S. Purity of food cooked in stainless steel utensils. Food Addit
Contam 1997;14(2):115-26. https://doi.org/10.1080/02652039709374506.
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
total diet study. 2014 [available at https://www.food.gov.uk/research/research-projects/
total-diet-study-metals-and-other-elements-from-the-2014-uk-total-diet-study.pdf,
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FSA Total diet study: metals and other elements. 2019 [available at https://www.food.gov.uk/
research/research-projects/total-diet-study-metals-and-other-elements?navref=search-
global-research-3, accessed 17 Nov 2022].
FSA. Survey on measurement of the concentrations of metals and other elements from the
2006 UK Total Diet Study. Food Survey Information Sheet 01/09. Referenced in: Rose M,
Baxter M, Brereton, et al. Dietary exposure to metals and other elements in the 2006 UK
Total Diet Study and some trends over the last 30 years. Food Addit Contam Part A Chem
Anal Control Expo Risk Assess 2010;27(10):1380-404. https://doi.org/10.1080/19440049.2010
.496794.
Ni

Hedberg Y, Mazinanian N, Wallinder IO. Compliance tests of stainless steel as a food

contact material using the CoE test guideline. KTH Royal Institute of Technology. Decem-
ber 2014 [available at http://bit.ly/1USTJjn, accessed 17 Nov 2022].
ICH. Guideline for elemental impurities Q3D(R1). March 2019 [available at https://database.
ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_Guideline_2019_0322.pdf,
accessed 17 Nov 2022].
Klein CB and Costa M. Nickel. In: Nordberg GF, Costa M, editors. Handbook on the tox-
icology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
2022. https://doi.org/10.1016/B978-0-12-822946-0.00022-2.
Kuligowski J, Halperin KM. Stainless steel cookware as a significant source of nickel, chro-
mium, and iron. Arch Environ Contam Toxicol 1992;23(2):211-15. https://doi.org/10.1007/
BF00212277.
Mazinanian N, Herting G, Odnevall Wallinder I, et al. Metal Release and Corrosion
Resistance of Different Stainless Steel Grades in Simulated Food Contact. Corrosion
2016;72(6):775-90. https://doi.org/10.5006/2057.

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National Food Agency of Denmark. Food monitoring 1988-1992. Publication No 232. Min-
istry of Health, Copenhagen; December 1995.
Nickel Institute. First use of nickel. 2022 [available at https://nickelinstitute.org/en/about-
nickel-and-its-applications/#04-first-use-nickel, accessed 21 Nov 2022].
Nielsen GD, Søderberg U, Jørgensen PJ, et al. Absorption and retention of nickel from
drinking water in relation to food intake and nickel sensitivity. Toxicol Appl Pharmacol
1999;154(1):67-75.
Parkinson R. Properties and applications of electroless nickel. NiPERA 2001 [available at
https://www.nichro.dk/pdf/PropertiesAndApplicationsOfElectrolessNickel_10081_.pdf,
accessed 21 Nov 2022].
Sirot V, Traore T, Guérin T, et al. French infant total diet study: Exposure to selected
trace elements and associated health risks. Food Chem Toxicol 2018;120:625-33. https://doi.
org/10.1016/j.fct.2018.07.062.
Sunderman FW Jr, Hopfer SM, Sweeney, KR, et al. Nickel absorption and kinetics in human
volunteers. Proc Soc Exp Biol Med 1989;191(1):5-11. https://doi.org/10.3181/00379727-191-42881.
Tietz T, Zellmer S, Ebner I, et al. Derivation of a TDI for the oral uptake of nickel by
means of Benchmark Dose Modelling of data from a two generation study on reproduc-
tion toxicity. European Society of Toxicology In Vitro (ESTIV) Congress 2018 [available
at https://www.researchgate.net/publication/340232498_Derivation_of_a_TDI_for_the_
oral_uptake_of_nickel, accessed 20 September 2021].
Veien NK. Nickel dermatitis: its relationship to food and experimental oral challenge. In:
Maibach HI, Menné T, editors. Nickel and the skin: Immunology and toxicology. Boca
Raton, Florida: CRC Press, Inc.; 1989: 165-78.
Veien NK, Menné T. Nickel contact allergy and a nickel-restricted diet. Semin Dermatol

Ni
1990;9(3):197-205.
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

107
 Silver (Ag)

Pure silver has the highest thermal and electrical

conductivity of all metals. Silver alloys containing
a minimum of 92.5% by weight of silver and
7.5% by weight of other metals, usually copper,
are known as sterling silver (Beliles, 1994).

Sources and levels of intake

In surface water and groundwater, silver concentrations are usually below
5 µg/L; however, detections > 100 µg/L, although rare, have been reported
(WHO, 2022).
Silver may be ingested via consumption of marine organisms containing
low concentrations, and in small amounts released from dental fillings
(Hedberg and Nordberg, 2022). The use of silver and silver nanoparticles
as antimicrobials and disinfectants is increasing (Hedberg and Nordberg,
2022). Silver is also used as a colouring agent for decorations in confection-
ery and in alcoholic beverages.

Ag
ANSES (2011) estimated mean daily intake between 1.29 and 2.65 µg/kg
bw/day (according to LB or UB assumptions) for adults and between 1.60
and 3.47 µg/kg bw/day for children.
In a recent study on infants and toddlers (ANSES, 2016; Sirot et al., 2018),
the daily intake was estimated to be negligible (0 µg/kg bw/day) in a LB
calculation both for mean and 90th percentile. For UB, a daily intake of
2.10-4.23 µg/kg bw/day (mean) and 2.97-5.35 µg/kg bw/day (90th percentile)
were calculated.
It has to be noted that although the cited studies are total diet studies, in the
course of which the samples were prepared ‘as consumed’, usage of silver

109
 Metals and alloys used in food contact materials and articles

tableware and cutlery were not covered by the study design. Hence, the
actual daily intake for consumers using these articles on a daily basis could
be higher.

Metallic food contact materials

Silver is used in the production of cutlery and tableware (Hedberg and
Nordberg, 2022).
Attention should be paid to the European standards EN ISO 8442-2 (ISO,
1997) and EN ISO 8442-3 (ISO, 1997) that apply to silver-plated nickel silver,
or silver-plated stainless steel cutlery and to silver-coated brass, copper,
nickel silver, pewter and stainless steel holloware and attachments thereto,
respectively.

Other food contact materials

The Provisional list of additives used in Plastics of Regulation (EC)
No 10/2011 for plastic FCM includes silver-containing substances. These
are surface biocides, used to protect the surface of finished articles from
microbial contamination during storage and subsequent use.

Release
Ag

The information on release of silver is limited. Pure silver is a moder-

ately soft metal (Beliles, 1994). Chemically, silver is the most reactive of
the noble metals, but it does not readily oxidise; instead it ‘tarnishes’ by
combining with sulfur or H2S. Nitric or sulfuric acids can oxidise silver to
the uni-positive ion, the form in which it exists in most of its compounds
(Beliles, 1994).

Safety aspects
• JECFA (1978) has reviewed the existing toxicological data (WHO, 1977)
and concluded that ‘no evaluation could be made’ due to insufficient data.

110
 Silver (Ag)

• Up to 10-20% of silver salts may be absorbed following ingestion (Hedberg

and Nordberg, 2022). The biological half-life of silver ranges from a few
days for animals up to about 50 days in the human liver (Hedberg and
Nordberg, 2022). Water-soluble silver compounds, such as silver nitrate,
have a local corrosive effect and may cause fatal poisoning if ingested
accidentally. Repeated exposure to silver may produce anaemia, cardiac
enlargement, growth retardation and degenerative changes in the liver
(Hedberg and Nordberg, 2022).
• According to EFSA (2016), ‘ionic silver is non-mutagenic in bacteria but
genotoxic and clastogenic in mammalian cells in vitro […]. No informa-
tion is available on the genotoxic potential of ionic silver in vivo.’
• Acute human toxicity from silver seems to be related to stimulation fol-
lowed by depression of structures in the brain stem (WHO, 1977). Symp-
toms are a rise in blood pressure, haemorrhagic gastroenteritis and
shock; 10 g of silver nitrate taken orally is considered to be a lethal dose
to man, (WHO, 1977). Some silver compounds such as silver oxide and
silver nitrate are irritants, and exposure is associated with nose-bleeds
and abdominal cramps (Beliles, 1994). High intake of silver, whether in
metal or ionic form can lead to renal and pulmonary lesions and argyria
or argyrosis. 0.6 mg/kg bw per day of colloidal silver was considered as
LOAEL based on a case report of argyria in a woman who ingested this
dose of silver for 16 months (WHO, 2022).
• EFSA (2016) summarised the acute toxicity in animals as follows: Accord-

Ag
ing to WHO (1977), the LD50 (mice) is 50 mg/kg bw as silver nitrate
(corresponding to 32 mg ionic silver/kg bw). According to Tamimi et al.
(1998), the LD50 in rats and rabbits is 428 and 1261 mg silver nitrate/kg
bw, respectively, corresponding to 280 and 794 mg ionic silver/kg bw,
respectively).
• There are few studies on subchronic or chronic exposure to silver. In
these, effects on the liver, bw, immune system and developmental toxicity
were observed – although data were not always consistent (especially for
immune toxicity). The lowest NOAEL (0.26 mg ionic silver/kg bw/day)
was identified for reproductive toxicity observed in a one-generation
study, where silver acetate was orally ingested via drinking water

111
 Metals and alloys used in food contact materials and articles

(Sprando et al., 2017). The NOAEL is based on reduced bw gain of the

pups and reduced numbers of implants and post-implantation loss.
However, it should be noted that the selection of the NOAEL is questiona-
ble, because the reduced bw was only observed in one dose group (middle
dose: 2.6 mg/kg bw/day), was not dose dependent, and could be explained
by a slightly increased number of pups. Reduced numbers of implants
and post-implantation loss were only observed in the high dose group
(26 mg/kg bw/day). Hence it would be possible to identify this dose as
LOAEL, resulting in a NOAEL of 2.6 mg ionic silver/kg bw/day. However,
in accordance with EFSA (2016), it should be concluded that the data are
not robust enough for derivation of a health-based guidance value.
• In 1980, the EPA analysed and described a series of experiments, conclud-
ing that silver ion concentrations > 0.2 mg/L in drinking water had no
harmful effect on laboratory animals that had been continuously ingest-
ing them for 11 months (EPA, 1980).
• The EPA has established a chronic oral RfD for silver ingestion of 5 μg/kg
bw/day on a review of 70 cases of argyria by oral route, last updated in
1991 (EPA, 1991). This value is not adapted for risk assessment in food
because of the lack of studies.
• WHO (2022) set a provisional reference value of 0.1 mg/L for silver. Avail-
able data are inadequate to permit the derivation of health-based guide-
line value.
• EFSA (2005) established a group restriction for substances containing
Ag

silver at 0.05 mg/kg food and concluded that this restriction would limit
the silver intake to less than 13% of the human NOAEL.
• Remark: FCM containing nanoscale silver have not been considered and
need to be evaluated separately on a case-by-case basis.

Conclusions and recommendations

the SRL for silver is set at 0.08 mg/kg food or food simulant

Given the lack of data and the lack of clarity associated with the
WHO-derived total lifetime oral intake of about 10 g, the intake data

112
 Silver (Ag)

from ANSES (2011) were used to derive the SRL. Using the lower value of
1.29 µg/kg bw/day (0.08 mg/day) and assuming that a person of 60 kg bw
consumes 1 kg of foodstuffs per day that is packaged and/or prepared with
FCM made from metals and alloys, the SRL is set at 0.08 mg/kg. Because
the limit was derived from intake data, no allowance for metallic FCM was
applied.
Silver or silver-plated cutlery, manufactured to be used for eating or serving
(not for cooking) and not on a daily basis, should be labelled accordingly.
When assessing their compliance, a reduction factor of 5 may be applied to
the SRL, when justified (see Annex II of Chapter 3).

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
ANSES. Étude de l’alimentation totale infantile – Tome 2 – Partie 2 Composés inor-
ganiques. [Infant Total Diet Study (iTDS) – Volume 2 – Part 2 Inorganic compounds].
September 2016 [available at https://www.anses.fr/en/content/infant-total-diet-study-itds,
accessed 20 Sep 2021].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
EC. Provisional list of additives used in Plastics. 2011 [available at https://food.ec.europa.
eu/system/files/2016-10/cs_fcm_legis_additives-prov-list.pdf, accessed 24 Nov 2022].
EFSA. Opinion of the Scientific Panel on food additives, flavourings, processing aids and

Ag
materials in contact with food (AFC) related to a 7th list of substances for food contact
materials. EFSA Journal 2005;3(4):201a. https://doi.org/10.2903/j.efsa.2005.201a.
EFSA. Opinion of the Scientific Panel on food additives, flavourings, processing aids and
materials in contact with food on a 4th list of substances for food contact materials. EFSA
Journal 2004;2(6);65. https://doi.org/10.2903/j.efsa.2004.65a.
EFSA. Scientific opinion on the re-evaluation of silver (E 174) as food additive. EFSA Panel
on Food Additives and Nutrient Sources added to Food. EFSA Journal 2016;14(1):4364.
https://doi.org/10.2903/j.efsa.2016.4364.
EPA. Ambient water quality criteria for silver. 1980 [available at https://www.epa.gov/sites/
default/files/2019-03/documents/ambient-wqc-silver-1980.pdf, accessed 24 Nov 2022].
EPA. Silver; CASRN 7440-22-4. 1991 [available at https://cfpub.epa.gov/ncea/iris/iris_
documents/documents/subst/0099_summary.pdf, accessed 24 Nov 2022].

113
 Metals and alloys used in food contact materials and articles

European Commission. Commission Regulation (EU) No 10/2011 of 14 January 2011 on

plastic materials and articles intended to come into contact with food. Official Journal of
the European Union 2011;54:1-89.
Gaul LE, Staud AH. Clinical spectroscopy: seventy cases of generalized argyrosis follow-
ing organic and colloidal silver medication, including a biospectrometric analysis of ten
cases. JAMA 1935;104(16):1387-90. https://doi.org/10.1001/jama.1935.02760160011004.
Hedberg Y, Nordberg GF. Silver. In: Nordberg GF, Costa M, editors. Handbook on the
toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
2022. https://doi.org/10.1016/B978-0-12-822946-0.00026-X.
ISO. Materials and articles in contact with foodstuffs – cutlery and table holloware – Part 3:
Requirements for silver-plated table and decorative holloware. Ref: ISO 8442-3:1997.
ISO. Materials and articles in contact with foodstuffs – cutlery and table holloware – Part 2.
Requirements for stainless steel and silver-plated cutlery. Ref:ISO 8442-2:1997.
JECFA. Evaluation of certain food additives. WHO Technical Report Series 617. 1978.
Sirot V, Traore T, Guérin T, et al. French infant total diet study: Exposure to selected
trace elements and associated health risks. Food Chem Toxicol 2018;120:625-33. https://doi.
org/10.1016/j.fct.2018.07.062.
Sprando RL, Black T, Keltner Z, et al. Silver acetate exposure: Effects on reproduction
and postnatal development. Food Chem Toxicol 2017;106:547-57. https://doi.org/10.1016/j.
fct.2016.06.022.
Tamimi SO, Zmeili SM, Gharaibeh MN, et al. Toxicity of a new antismoking mouth-
wash 881010 in rats and rabbits. J Toxicol Environ Health A 1998;53(1):47-60. https://doi.
org/10.1080/009841098159466.
WHO IPCS. Silver. WHO Food Additives Series 447. 1977 [available at http://www.inchem.
org/documents/jecfa/jecmono/v12je19.htm, accessed 20 Sept 2021].
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Ag

second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed

01 July 2023].

114
 Tin (Sn)

Tin occurs in the Earth’s crust with an average

abundance of 2 mg/kg and is concentrated in areas
of tin-bearing minerals, mainly as cassiterite or
tinstone (SnO2), which is the main source of tin
production (Beliles, 1994). Combustion of fossil fuels
releases small quantities of tin into the air (WHO,
2005). Secondary tin sources are general tin-, lead-
and copper-based alloys and, in particular, solder
from electrical and electronic devices. The recovered
tin is recycled within product-line industries and,
hence, is used again in alloys (Ostrakhovitch, 2022).

Sources and levels of intake

Inorganic tin is found in most foodstuffs; it may occur in a cationic form
(stannous and stannic compounds) or as inorganic anions (stannites or
stannates). Levels are generally less than 1 mg/kg in unprocessed foodstuffs.
Higher concentrations are found in canned foodstuffs due to dissolution of
the tinplate to form inorganic tin compounds or complexes (WHO, 2005).
A normal diet without canned foodstuffs or beverages contains approxi-
Sn
mately 0.2 mg tin/day (WHO, 2005). The total average dietary intake of tin
is 4 mg/day (Beliles, 1994). More recently, in the 2014 UK Total Diet Study
the highest total mean and 97.5th percentile exposures were in the 1.5 to 3
years age class and were 95-96 μg/kg bw/day and 300 μg/kg bw/day, respec-
tively. The highest contributing food group to total mean exposure was
‘canned vegetables’ with a mean exposure of 61 μg/kg bw/day (FSA, 2014).

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 Metals and alloys used in food contact materials and articles

ANSES (2011) estimated mean daily intake as total tin at 3.9 µg/person/day
in adults and 7.3 µg/person/day in children. The highest concentrations
were measured in stewed fruits (8.55 mg/kg) and cheese (1.94 mg/kg).

Metallic food contact materials

Tin is used in tinplated food cans and containers (Ostrakhovitch, 2022)
and the major source of tin in the diet is from FCM, especially the release
from tin cans to acidic foodstuffs (WHO, 2005). Tin cans are actually steel
cans with a thin coating of metallic tin (tinplate) (Beliles, 1994), and there
is often an internal resin-based coating on the tinplate. Tinplate is mainly
used in cans and closures and lids for glass bottles and jars. Tin is also
found in pewter and used in alloys, e.g. with copper for conversion into
bronze and with zinc for galvanisation (Beliles, 1994). Tin is also used to
coat kitchen utensils.
While the use of tin in cans has decreased somewhat in recent years in the
USA, tinplate remains the largest tin use sector in the EU, where quantities
employed have been stable for several years. There is significant growth in
tinplate use in other regions.

Other food contact materials

Direct applications include the use of mixed tin oxide-metal oxide systems
as pigments. The other commercial applications of inorganic tin com-
pounds are in the ceramics and glass industries (Ostrakhovitch, 2022).
Tin(IV) oxide is used both as an opacifier and as a constituent of coloured
Sn

pigments in high-quality tableware, e.g. bone china and porcelain prod-

ucts. Thin tin(IV) oxide films on glass can also be used to strengthen and
provide scratch-resistance to beer glasses, milk bottles, etc.

Release
Tin is amphoteric, reacting with both strong acids and bases, but is rela-
tively non-reactive with nearly neutral solutions (Beliles, 1994). The pres-
ence of oxygen greatly accelerates reactivity in solution (Beliles, 1994).

116
 Tin (Sn)

Tinplate used in food containers is only slowly oxidised. The tin content in
foodstuffs depends on:
– whether the tin cans are lacquered;
– the presence of any oxidising agents or corrosion accelerators (e.g.
nitrate);
– the acidity of the product in the tin can;
– how long, and at what temperature, the tin cans are stored before being
opened;
– the length of time the product is kept in the tin can after it has been
opened.
Oxidation of tinplate, followed by the release of tin ions into the foodstuff is
known as a ‘sacrificial anode effect’, a physiochemical mechanism that pro-
tects the underlying steel from corrosion. The dissolution of tin protects the
can from possible perforation and protects the contents from degradation
(changes in colour and flavour) during heat sterilisation and storage.
The concentration of tin in foodstuffs stored in unlacquered cans may
exceed 100 mg/kg, whereas foodstuffs stored in lacquered cans show tin
levels generally below 25 mg/kg (WHO, 2005). Storing foodstuffs in opened
unlacquered cans results in substantial increases in the tin concentration in
the foodstuffs (WHO, 2005). Fruits and vegetables consumed from unlac-
quered cans make up only a small percentage of dietary intake (by weight
of total food intake), but their contribution to dietary tin intake amounts
to 85%. The thickness of the lacquer coating greatly influences the perfor-
mance of the lacquered food can (WHO, 2005).
An oxide film forms on metallic tin on exposure to air, whether in the pure
Sn
form or as an alloy, and not just on dipped and electroplated tin. The film
is fairly stable and provides a barrier to further oxidation. At pH values
between 3 and 10 and in the absence of complexing agents, the oxide barrier
protects the metal from the food. Outside this pH range, however, corro-
sion of the tin occurs (Murphy and Amberg-Muller, 1996).
Pewter may contain lead as a contaminant, which can also be released.
Antique pewter may have been manufactured using lead-containing alloys,

117
 Metals and alloys used in food contact materials and articles

but this is not the case with modern pewter. Today, maximum levels of lead
are specified for lead-containing pewter.

Safety aspects
• JECFA (1989) established in 1988 a PTWI of 14 mg/kg bw/week including
tin from food additives. JECFA also states that ‘tin levels should be as low
as practicable because of possibility of gastric irritation’. In 2005, JECFA
maintained the PTWI of 14 mg/kg/week.
• WHO (2022) has concluded that, because of its low toxicity, the estab-
lishment of a guideline value for inorganic tin was not deemed necessary.
• Codex Standard 193-1995 fixed a maximum limit of 250 mg/kg for tin
in canned foods and a maximum level of 150 mg/kg for tin in canned
beverages.
• According to Regulation (EC) No 1333/2008 of the European Parliament
and of the Council of 16 December 2008 on food additives, stannous
chloride is authorised as a food additive for canned and bottled aspara-
gus (only white asparagus) up to 25 mg/kg (as tin).
• There are no indications of chronic tin toxicity in humans (WHO, 2005).
Inorganic tin compounds are poorly absorbed from the gastrointesti-
nal tract (less than 5%) (Ostrakhovitch, 2022). Tin compounds act as an
irritant for the gastrointestinal tract mucosa, causing nausea, vomiting,
diarrhoea, fatigue and headache (WHO, 2005). Only a limited number
of cases indicating possible gastrointestinal irritation have been reported
following the consumption of canned fruit juices, tomatoes, cherries,
Sn

asparagus, herrings and apricots. The exact concentrations of tin were

unknown in these cases of assumed acute poisoning, but were proba-
bly in the range of 300-500 mg/kg (WHO, 1980). Earlier studies suggest
that tin might interfere with iron absorption and haemoglobin formation.
Tin also has an inhibitory effect on copper, zinc and calcium absorption
(WHO, 2005). Chronic exposure to high levels of tin may result in growth
depression and altered immune function, possibly due to interactions
between tin and zinc or selenium (WHO, 2005).

118
 Tin (Sn)

• EFSA (2006) quoted a study recording a decrease in zinc assimilation

following absorption of 50 mg/day of SnCl2. EFSA assessed tin in 2005,
but considered the available data insufficient to derive a tolerable upper
intake level. They noted that current daily intakes in the EU, ranging up
to 6 mg/day in the UK, appear to be well below levels associated with
adverse effects.
• In their assessment, the EVM (2003) could not establish a safe upper
level, but considered that 0.22 mg/kg bw/day (13.2 mg/day) would not
be expected to produce adverse effects in humans. This was based on a
NOAEL for liver cell changes and anaemia of 22-33 mg/kg bw/day from
a subchronic study in rats with uncertainty factors of 10 for interspecies
and 10 for intraspecies variation.
• The COT, in their 2008 statement, considered that the PTWI is not
directly applicable to long-term dietary exposure as it appears to be based
on acute toxicity. Therefore, the EVM’s assessment was used as a guidance
level. While dietary exposure for high-level intake by pre-school children
exceeded the EVM guidance level by approximately 55%, all other esti-
mated subgroup dietary exposures (mean- and high-level intakes) were
within the EVM guidance level. Hence, the COT concluded that the
slight exceedance of this guidance level is within an area of uncertainty,
but that current dietary exposures were unlikely to be of toxicological
concern.
• In 2010, the ‘REACH Tin Metal Consortium’ conducted a 28-day,
repeated dose, oral toxicity study in rats with tin as powder. Multiple
endpoints were investigated and no adverse effects were detected, even at
the highest dose (1 000 mg/kg bw/day). However, the study was consid- Sn
ered inadequate because tin was administered in powder form, which is
not representative of human dietary exposure.
• According to Commission Regulation (EU) 2023/915 setting maximum
levels for certain contaminants in foodstuffs, the maximum levels of tin
(inorganic) are:
– 50 mg/kg for certain canned foods for babies and young children
– 50 mg/kg canned dietary foods for special medical purposes for infants

119
 Metals and alloys used in food contact materials and articles

– 100 mg/kg for canned beverages, including fruit juices and vegetable
juices
– 200 mg/kg for canned foods other than beverages.

Conclusions and recommendations

the SRL for tin is set at 100 mg/kg food or food simulant

Food contact with tin materials exposed to air should be avoided at low pH
and high temperatures as the ‘sacrificial effect’ afforded by sealed tin-plated
cans is lost and the underlying steel is no longer protected.
Consumers should be advised against storing food in opened tin-plated
cans.
In view of the observed acute effects (gastric irritation) the SRL for tin is set,
in approximation to Commission Regulation (EU) 2023/915, at 100 mg/kg.
This limit does not apply to food contact applications that are covered by
Commission Regulation (EU) 2023/915.
The lower limit for babies and young children was not considered because
exposure of children to tin from food contact applications that are not
covered by Regulation (EC) No 1881/2006 is negligible (Foster, 2010).

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Sn

Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
Codex Alimentarius International Food Standards. General Standard for Contaminants
and Toxins in Food and Feed. CXS 193-1995. Adopted 1995; Revised 1997, 2006, 2008,
2009; Amended 2009, 2010, 2012, 2013, 2014, 2015, 2016, 2017, 2018, 2019 [available at
https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%
252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXS%2B193-
1995%252FCXS_193e.pdf, accessed 24 Nov 2022].

120
 Tin (Sn)

COT. Statement on the 2006 UK Total Diet Study of Metals and Other Elements. Decem-
ber 2008 [available at https://cot.food.gov.uk/sites/default/files/cot/cotstatementtds200808.
pdf, accessed 21 Nov 2022].
EFSA. Opinion of the NDA related to the tolerable upper intake level of tin. August 2005
[available at https://efsa.onlinelibrary.wiley.com/doi/10.2903/j.efsa.2005.254, accessed
21 Nov 2022].
EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
8546-fb176a685e13, accessed 17 Nov 2022].
EC. Commission Regulation (EU) 2023/915 of 25 April 2023 on maximum levels for certain
contaminants in food and repealing Regulation (EC) No 1881/2006. Official Journal of the
European Union 2023;L 119/103.
European Parliament. Regulation (EC) No 1333/2008 of the European Parliament and of
the Council of 16 December 2008 on food additives. Official Journal of the European Union
2008;51:16-33.
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/cot/vitmin2003.pdf, accessed 17 Nov 2022].
Foster E, Mathers JC, Adamson AJ. Packaged food intake by British children aged 0 to 6
years. Food Addit Contam Part A Chem Anal Control Expo Risk Assess 2010;27(3):380-8.
https://doi.org/10.1080/19440040903367161.
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/research/research-projects/
total-diet-study-metals-and-other-elements, accessed 17 Nov 2022].
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 776. 1989.
JECFA. Evaluation of certain food contaminants. WHO Technical Report Series 930. 2005.
Murphy TP, Amberg-Muller JP. Metals. In: Katan LL, editor. Migration from Food Contact
Materials. Glasgow, United Kingdom: Blackie Academic and Professional; 1996: 111-44.
Ostrakhovitch EA. Tin. In: Nordberg GF, Costa M, editors. Handbook on the toxicology of Sn
metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press; 2022. https://
doi.org/10.1016/B978-0-12-822946-0.00029-5.
WHO IPCS. Tin and organotin compounds: a preliminary review. Environmental Health
Criteria 15. 1980 [available at https://apps.who.int/iris/handle/10665/39658, accessed
21 Nov 2022].
WHO IPCS. Tin and Inorganic Tin Compounds. Concise International Chemical Assess-
ment Document 65. 2005 [available at https://apps.who.int/iris/handle/10665/43223,
accessed 21 Nov 2022].

121
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
26 June 2023].
 Titanium (Ti)

Titanium is the ninth most common element

in the Earth’s crust and occurs in a number of
minerals (Beliles, 1994). Titanium is a silvery-
grey metal resembling polished steel (Beliles, 1994).
There is no evidence indicating that titanium is an
essential element for humans (Jin et al., 2022).

Sources and levels of intake

In the EU, titanium dioxide was used as a food additive (E 171) until 2022
and is still used in toothpastes, sunscreens and pharmaceuticals.
As of August 2022, the use of E 171 titanium dioxide as a food additive is
banned in Europe. Titanium dioxide is not authorised in the food cate-
gories listed in Annex II (Part D and E) of Regulation (EC) No 1333/2008
as amended by Commission Regulation (EU) No 2022/63. Until
7 August 2022, foods produced in accordance with the rules applicable
before 7 February 2022 could continue to be placed on the market. After
that date, they may remain on the market until their date of minimum
durability or ‘use by’ date (Regulation (EU) No 2022/63).
The EC ‘shall, following consultation on the European Medicines Agency,
review the necessity to maintain titanium dioxide (E 171) or to delete it from
the Union list of food additives for the exclusive use as colour in medicinal
Ti

products in Part B of Annex II to Regulation (EC) No 1333/2008 within three

years after the date of entering into force’ of Regulation (EU) No 2022/63.
In the UK, the use of titanium dioxide as a food colour is still permitted,
and there is no indication that the UK will follow the EU at this time. The
FSA and FSS have launched their own independent risk assessment of the
safety of titanium dioxide when used as a food and feed additive and any

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 Metals and alloys used in food contact materials and articles

risk management action will be informed by this risk assessment (COT,

2022).

Metallic food contact materials

Titanium is often used in the form of alloys that are stronger and more
resistant to corrosion than the metal itself (Jin et al., 2022). Titanium has
been suggested for use with corrosive or delicate liquids such as dairy prod-
ucts, fruit juices and in the wine industry (Feliciani et al., 1998). Titanium
is also used in certain so-called ‘stabilised’ forms of stainless steels, which
in general contain less than 1% titanium.

Other food contact materials

The extreme whiteness and brightness of titanium dioxide has led to its
extensive use as a white pigment in paints, lacquers, enamels, paper-coatings
and plastics (Beliles, 1994; Jin et al., 2022). Titanium compounds are also
used as catalysts in the manufacture of plastics.

Release
Titanium seems to be practically inert, due to the phenomenon of pas-
sivation of the titanium surface by the formation of a molecular layer of
TiO2. This layer, which is very adherent to the metallic substrate, is hardly
removed even by aggressive 3% v/v acetic acid solution saturated with
18-20% sodium chloride (Feliciani et al., 1998).

Safety aspects
Ti

• Titanium dioxide was assessed by JECFA in 1969 and an unlimited ADI

was determined (JECFA, 1970).
• The estimated intake of titanium is 0.3-1 mg/day (Beliles, 1994; White-
head, 1991).

124
 Titanium (Ti)

• Titanium compounds are generally considered to be poorly absorbed

upon ingestion (Jin et al., 2022). Studies on titanium alloys used in
implants and titanium compounds used in cosmetics and pharmaceuti-
cals do not indicate any significant local tissue effects (Jin et al., 2022). A
distinct toxicological dichotomy exists between TiO2, the insoluble, unre-
active non-metabolised form that is devoid of toxicity, and the soluble,
inorganic salts that metabolise normally with absorption, distribution,
and excretion (Beliles, 1994).
• EFSA (2021) provided an updated safety assessment of the food additive
titanium dioxide (E 171) taking into account all new relevant data avail-
able to them. Along with all the uncertainties, in particular the fact that
genotoxicity concern could not be ruled out, EFSA concluded that E 171
can no longer be considered as safe when used as a food additive.
The 2021 opinion by EFSA applies only to E 171 as specified in the 2019
opinion and as described in Commission Regulation (EU) 2022/63 (amend-
ing Commission Regulation (EU) No 1333/2008).

Conclusions and recommendations

it is appropriate not to set any SRL for titanium

At the moment, it is appropriate not to set any SRL for titanium. Measures
related to the use of E 171 as an additive in FCM and articles (e.g. plastics or
coatings) may follow EFSA’s 2019 Opinion.

References
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
Ti

COT. Interim position paper on titanium dioxide. 2022 [available at https://cot.food.

gov.uk/sites/default/files/2022-01/TiO2%20COT%20Interim%20position%20paper.pdf,
accessed 25 Nov 2022].
EFSA. Scientific opinion on the proposed amendment of the EU specifications for titanium
dioxide (E 171) with respect to the inclusion of additional parameters related to its particle
size distribution. EFSA Journal 2019;17(7):5760. https://doi.org/10.2903/j.efsa.2019.5760.

125
 Metals and alloys used in food contact materials and articles

EFSA. Scientific Opinion on the safety assessment of titanium dioxide (E 171) as a food
additive. EFSA Journal 2021;19(5):6585. https://doi.org/10.2903/j.efsa.2021.6585.
European Parliament. Regulation (EC) No 1333/2008 of the European Parliament and of
the Council of 16 December 2008 on food additives. Official Journal of the European Union
2008;51:16-33.
EC. Regulation (EU) No 231/2012 of 9 March 2012 laying down specifications for food addi-
tives listed in Annexes II and III to Regulation (EC) No 1333/2008 of the European Parlia-
ment and of the Council. Official Journal of the European Union 2012;55:1-295.
EC. Regulation (EU) 2022/63 of 14 January 2022 amending Annexes II and III to Regula-
tion (EC) No 1333/2008 of the European Parliament and of the Council as regards the food
additive titanium dioxide (E 171). Official Journal of the European Union 2022;65:1–5.
Feliciani R, Migliorelli D, Maggio A, et al. Titanium: a promising new material for food
contact. A study of titanium resistance to some aggressive food simulants. Food Addit
Contam 1998;15(2):237-42. https://doi.org/10.1080/02652039809374635.
JECFA. Specifications for the identity and purity of food additives and their toxicological
evaluation. WHO Technical Report Series 445. 1970.
Jin T, Costa M and Chen X. Titanium. In: Nordberg GF, Costa M, editors. Handbook on
the toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic
Press; 2022. https://doi.org/10.1016/B978-0-12-822946-0.00030-1.
Whitehead J. Titanium. In: Merian E, Clarkson TW, editors. Metals and their compounds
in the environment: Occurrence, analysis, and biological relevance. VCH Publishing; 1991.
Ti

126
 Vanadium (V)

Vanadium is a white, shiny, soft, ductile metal. It is

highly resistant to corrosion by alkali compounds
as well as hydrochloric and sulfuric acids. It is to be
found in some ores and it is mainly used in alloys.

Sources and levels of intake

Vanadium is mainly found in seafood and mushrooms, but also in many
fruits and vegetables, albeit in very low quantities.
In the USA, dietary intake was estimated in the range of 6-18 μg/day for
adults (Pennington and Jones, 1987). Results from a duplicate diet study
in Spain estimated the dietary intake of vanadium equal to 156 µg/day
(Domingo et al., 2012).
ANSES (2011) estimated mean daily intake at 52 µg/day (0.86 µg/kg bw/day)
in adults and 1.06 µg/kg bw/day in children.

Metallic food contact materials

Vanadium can be used in alloys to manufacture tools such as knife blades.
Vanadium steel is extremely well suited to the manufacture of tools such
as knives and parts for rotating machinery. Adding vanadium to steel in
proportions of approximately 1% produces a highly shock-resistant alloy.
In France, MCDA n°1 (V02 – 01/04/2017) on food contact suitability of
metals and alloys specifies acceptance criteria for vanadium amounts in
V

steel.

127
 Metals and alloys used in food contact materials and articles

Other food contact materials

Vanadium oxide is used in ceramic pigments.

Release
No information available.

Safety aspects
• The EVM (2003) has assessed vanadium but could not derive an upper
limit.
• The American Food and Nutrition Board (FNB, 2001) derived an upper
limit of 1.8 mg/day for vanadium. This value was derived from a LOAEL of
7.7 mg/kg bw/day (460 mg/day) from a rat study, an average bw of 68.5 kg
and an uncertainty factor of 300. This upper limit was also adopted by
Health Canada. However, Health Canada has stated: ‘Although vanadium
in food has not been shown to cause adverse effects in humans, there is
no justification for adding vanadium to food and vanadium supplements
should be used with caution. The upper limit is based on adverse effects
in laboratory animals and this data could be used to set an upper limit for
adults but not children and adolescents’ (Health Canada, 2017).
• EFSA (2006; 2009) reviewed the findings of FNB (2001). The absence of a
NOAEL and limited dose-response data prevented the EFSA from deriv-
ing an upper limit. Furthermore, the EFSA noted that vanadium has been
observed as having adverse effects on kidneys, spleen, lungs and blood
pressure in animals. In addition, developmental toxicity has also been
seen in the offspring of rats. However, it was noted that an exposure of
0.01 to 0.02 mg/day is at least three orders of magnitude below the dose
which causes gastrointestinal effects in body-builders taking vanadium
as supplements (EFSA, 2006; 2009).
• According to ICH Q3D(R1), the oral vanadium PDE is 120 µg/day.
V

128
 Vanadium (V)

Conclusions and recommendations

the SRL for vanadium is set at 0.01 mg/kg food or food simulant

It was decided to follow the opinion issued by EFSA. Given the toxicity
data and potential for adverse health effects, an SRL determined using the
FNB/Health Canada upper limit cannot be supported. Therefore, it was
agreed to base the SRL on the EFSA exposure data. Using the lower esti-
mated intake of 0.01 mg/day and assuming that a person of 60 kg bw con-
sumes 1 kg of foodstuffs per day that is packaged and/or prepared with FCM
made from metals and alloys, the SRL for vanadium is set at 0.01 mg/kg.
Since the SRL has been derived from exposure data, the use of an allocation
factor is not deemed necessary.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Direction générale de la concurrence, de la consommation et de la répression des fraudes
(DGCCRF). Fiche MCDA n°1 (V02 – 01/04/2017). Aptitude au contact alimentaire des
métaux et alliages destinés à entrer en contact avec des denrées alimentaires [Food contact
suitability of metals and alloys]. 2017 [available at https://www.economie.gouv.fr/files/files/
directions_services/dgccrf/securite/produits_alimentaires/materiaux_contact/fiches-
metaux-alliages-v2.pdf, accessed 17 Nov 2022].
Domingo JL, Perelló G, Giné Bordonaba J. Dietary intake of metals by the population of
Tarragona County (Catalonia, Spain): results from a duplicate diet study. Biol Trace Elem
Res 2012;146(3):420-5. https://doi.org/10.1007/s12011-011-9269-5.
EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
8546-fb176a685e13, accessed 17 Nov 2022].
EFSA. Vanadium citrate, bismaltolato oxo vanadium and bisglycinato oxo vanadium
added for nutritional purposes to foods for particular nutritional uses and foods (includ-
ing food supplements) intended for the general population and vanadyl sulfate, vanadium
pentoxide and ammonium monovanadate added for nutritional purposes to food supple-
ments – Scientific Opinion of the Panel on Food Additives, Flavourings, Processing Aids
V

and Materials in Contact with Food. EFSA Journal 2008;6(2);634. https://doi.org/10.2903/j.

efsa.2008.634.

129
 Metals and alloys used in food contact materials and articles

EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/cot/vitmin2003.pdf, accessed 17 Nov 2022].
American Food and Nutrition Board (FNB). Dietary Reference Intakes for Vitamin A,
Vitamin K, Arsenic, Boron, Chromium, Copper, Iodine, Iron, Manganese, Molybdenum,
Nickel, Silicon, Vanadium, and Zinc. 2001 [available at https://doi.org/10.17226/10026,
accessed 22 Nov 2022].
Health Canada. Reference Guide to Understanding and Using the Data 2015 Canadian
Community Health Survey – Nutrition. 2017 [available at https://www.canada.ca/en/
health-canada/services/food-nutrition/food-nutrition-surveillance/health-nutrition-
surveys/canadian-community-health-survey-cchs/reference-guide-understanding-using-
data-2015.html, accessed 22 Nov 2022].
ICH. Guideline for elemental impurities Q3D(R1). March 2019 [available at https://database.
ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_Guideline_2019_0322.pdf,
accessed 17 Nov 2022.
Pennington JA, Jones JW. Molybdenum, nickel, cobalt, vanadium, and strontium in total
diets. J Am Diet Assoc 1987;87(12):1644-50. https://doi.org/10.1016/S0002-8223(21)03381-2.
V

130
 Zinc (Zn)

Zinc is an essential trace metal (Wolf et al., 2022).

It is the 25th most abundant element and is widely
found in nature (Beliles, 1994). Zinc appears in
the form of zinc ions or zinc salts. Galvanising, a
process involving the coating of iron and steel with
zinc to prevent corrosion, is the most important
use of zinc (Beliles, 1994). Zinc protects iron from
rusting because it is a stronger reducing agent
(Beliles, 1994). Zinc is also used in fertilisers.

Sources and levels of intake

Zinc occurs in most foodstuffs and beverages (ATSDR, 2005). The main
contributors to zinc intake are meats, especially offal, whole grain cereals
and milk products including cheese. Oysters and peanuts may contain up
to 100 mg/kg and 30 mg/kg zinc, respectively.
In the 2014 UK Total Diet Study, the highest total mean and 97.5th percen-
tile exposures were in the 1.5 to 3 years age class and were 320 μg/kg bw/day
and 530 μg/kg bw/day, respectively. The highest contributing food groups
to total mean exposure were ‘miscellaneous cereals’ and ‘dairy products’
with a mean exposure of 51 μg/kg bw/day (FSA, 2014). More recently results
from a duplicate diet study in Spain estimated the dietary intake of zinc
equal to 6.8 mg/day (Domingo et al., 2012). In Ireland the mean and 95th
percentile intake from all sources including supplements were equal to
10.4 mg/day and 19.4 mg/day, respectively (IUNA, 2011). ANSES (2011) esti-
mated for adults the mean daily intake at 7.9 mg/day and the 95th percentile
at 13.3 mg/day.
Zn

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 Metals and alloys used in food contact materials and articles

Metallic food contact materials

A major use of zinc is the production of alloys, including brass, bronze and
galvanised steel (Wolf et al., 2022). Metallic zinc is commonly used to coat
iron or other metals so that they do not rust or corrode (ATSDR, 2005).
Zinc compounds are further used in household applications (Wolf et al.,
2022). The use of FCM made of zinc, zinc alloys or galvanised zinc is limited.
Zinc-coated steels are used in silos for storing foodstuffs.

Other food contact materials

Zinc sulfide is grey-white or yellow-white, and zinc oxide is white. Both
of these salts are used to make white paints, ceramics, and several other
products (ATSDR, 2005).

Release
Galvanised iron containers holding acidic drinks such as orange juice or
alcoholic beverages have resulted in a number of reports of poisoning. Zinc
is easily dissolved in dilute acids and by bases (Beliles, 1994). Zinc galva-
nised utensils may release zinc and cadmium. They can also release zinc
hydrocarbonate in confined spaces when exposed to air and humidity.
Data on the release of zinc from FCM and articles are scarce. One study, a
survey of teapots, showed zinc release of between 0.9 mg/L and 40 mg/L
using a citric acid solution (1 g/L) as simulant and a contact time of
30 minutes (Bolle et al., 2011).

Safety aspects
• JECFA (1982) established a PMTDI of 0.3-1 mg/kg bw/day.
• The required daily intake for adults is about 15 mg/day. However, the
requirement varies with age (JECFA, 1982).
Zn

132
 Zinc (Zn)

• WHO (2022) stated that derivation of a health-based guideline value for

drinking water was not required. However, drinking water containing
levels above 3 mg/L may not be acceptable to consumers.
• Zinc is one of the most ubiquitous of the essential trace metals (Florence
et al., 1980). The absorption rate is inversely related to the zinc intake
and ranges from 16% to 50% but can be increased in zinc deficiency up to
92% in a low-phytate diet (Wolf et al., 2022). Zinc is an essential element
necessary for the functioning of a large number of metallo-enzymes
(ATSDR, 2005; Beliles, 1994). Zinc acts to reduce the toxicity of cadmium
and copper (Florence et al., 1980). Zinc may be a modifier of the car-
cinogenic response; zinc deficiency or excessively high levels of zinc may
enhance susceptibility to carcinogenesis (Beliles, 1994).
• In their assessment, the EVM (2003) derived a safe upper level of
0.42 mg/kg bw/day (25 mg/day) for supplemental zinc. This is based on a
LOAEL of 50 mg/person/day for the inhibition of erythrocyte superox-
ide dismutase (eSOD) by zinc, associated with a mild copper deficiency.
An uncertainty factor of 2 was used for LOAEL to NOAEL extrapolation
as the effect is a small inconsistent change in a biochemical parameter.
Assuming a maximum intake of 17 mg/person/day from food, a total
intake of 0.7 mg/kg bw/day would not be expected to result in any adverse
effect.
• The SCF (2003) and EFSA (2006) interpreted, for the same endpoint
(inhibition of eSOD), the value of 50 mg/day as the NOAEL. Using an
uncertainty factor of 2 to account for the small number of subjects sur-
veyed, the upper limit was set to 25 mg/day. Furthermore, for children
aged 1-3 years, an upper limit of 7 mg/day was extrapolated from the adult
upper limit.
• In the 2008 European Risk Assessment Report, the overall oral NOAEL
of 50 mg/day was confirmed using the same studies as the SCF (2003).
However, no additional uncertainty factor was used. (JRC, 2008).
• ICH Q3D(R1): zinc is one of the elemental impurities for which PDEs
have not been established due to their low inherent toxicity.
Zn

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Conclusions and recommendations

the SRL for zinc is set at 5 mg/kg food or food simulant

It was decided to follow the opinion issued by the SCF (2003) and EFSA
(2006) with a derived upper limit of 25 mg/day.
Furthermore, intake data from multiple European countries to estimate
worst-case oral exposure from zinc were provided. The calculated worst-
case intake from food and supplements at the 95th percentile resulted in
a daily intake of 20 mg/day. Since this value is below the toxicologically
derived limit of 25 mg/day the difference of 5 mg/day can be allocated to
exposure from FCM made from metals and alloys.
Consequently, assuming that a person of 60 kg bw consumes 1 kg of food-
stuffs per day that is packaged and/or prepared with FCM made from
metals and alloys, the SRL for zinc is set at 5 mg/kg.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
ATSDR. Toxicological profile for zinc. US Department of Health & Human Services. 2005
[available at https://www.atsdr.cdc.gov/toxprofiles/tp60.pdf, accessed 22 Nov 2022].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
Bolle F, Brian W, Petit D, et al. Tea brewed in traditional metallic teapots as a significant
source of lead, nickel and other chemical elements. Food Addit Contam Part A Chem Anal
Control Expo Risk Assess 2011;28(9):1287-93. https://doi.org/10.1080/19440049.2011.580010.
Domingo JL, Perelló G, Giné Bordonaba J. Dietary intake of metals by the population of
Tarragona County (Catalonia, Spain): results from a duplicate diet study. Biol Trace Elem
Res 2012;146(3):420-5. https://doi.org/10.1007/s12011-011-9269-5.
EFSA. Tolerable upper intake levels for vitamins and minerals. SCF. NDA. February 2006
[available at https://op.europa.eu/en/publication-detail/-/publication/3748ff41-1c4a-4232-
8546-fb176a685e13, accessed 17 Nov 2022].
EVM. Safe Upper Levels for Vitamins and Minerals. May 2003 [available at https://cot.
food.gov.uk/sites/default/files/cot/vitmin2003.pdf, accessed 17 Nov 2022].
Zn

134
 Zinc (Zn)

Florence TM, Batley GE, Benes P. Chemical speciation in natural waters. Crit Rev Anal
Chem 1980;9:3:219-96. https://doi.org/10.1080/10408348008542721.
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/research/research-projects/
total-diet-study-metals-and-other-elements, accessed 17 Nov 2022].
ICH. Guideline for elemental impurities ICH Q3D(R1). March 2019 [available
at https://database.ich.org/sites/default/files/Q3D-R1EWG_Document_Step4_
Guideline_2019_0322.pdf, accessed 17 Nov 2022.
Irish Universities Nutrition Alliance (IUNA). National Adult Nutrition Survey. 2011 [avail-
able at https://www.iuna.net/surveyreports, accessed 24 Nov 2022].
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 683. 1982.
EC JRC. Risk assessment report: Zinc oxide. R073_0805_env; 2008 [available at https://
echa.europa.eu/documents/10162/596b1f42-8bfe-48f8-86f4-cd98fe6b7041, accessed
22 Nov 2022].
SCF. Opinion of the SCF on the tolerable upper intake level of Zinc, EC, 2003.
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
28 June 2023].
Wolf J, Sandstead HH and Rink L. Zinc. In: Nordberg GF, Costa M, editors. Handbook on
the toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic
Press; 2022. https://doi.org/10.1016/B978-0-12-822946-0.00034-9.

Zn

135
 Zirconium (Zr)

Zirconium is the 20th most common element in

the Earth’s crust and is found as compounds in
many mineral forms. It does not occur in nature as
a free element. Zirconium most commonly occurs as
zircon (ZrSiO4) and as baddeleyite (ZrO2 or zirconia).
There is no evidence that zirconium is essential
to man. Zirconium is highly resistant to heat and
corrosion. It is primarily used in metallic materials
within the aviation and aerospace industries, in
chemical and surgical instruments and in nuclear
reactor technology. Other products that contain
zirconium compounds include cosmetics and jewellery.
Zirconium is also used for the manufacture of cast
iron, steel, ceramics, enamels, paints, pigments,
preservatives, coatings, abrasives, refractories, tanning
agents and water repellents (NLM HSDB; ILO, 2011).

Sources and levels of intake

Zirconium is a naturally occurring and widely distributed element. It is
present at concentrations ranging from 150 to 300 mg/kg within the Earth’s
crust (NLM HSDB) and about 0.026 μg/L in seawater (Peterson et al., 2007).
Zirconium compounds can be released into the air and surface or ground
water through weathering of rocks and soils and are taken up by plants,
including edible fruits and vegetables (Ghosh et al., 1992). Zirconium can
be found in all animal tissues, generally below 10 µg/g wet tissue (Health
Council of the Netherlands, 2002). In food products, elevated levels of zir-
conium have been found in lamb, pork, eggs, dairy products, grains and

137
Zr
 Metals and alloys used in food contact materials and articles

vegetables, with concentrations generally varying between 3 and 10 ppm

(NLM HSDB).
Exposure can occur through the inhalation of ambient air containing low
levels of zirconium, ingestion of certain foods and via dermal contact with
consumer products containing zirconium compounds, such as cosmetics.
Estimations of the daily oral intake of zirconium in man vary from 3.5 to
4 mg, but have been reported to be as high as 125 mg. The average body
burden is 260 mg (NLM HSDB).

Metallic food contact materials

Zirconium is used in a wide variety of materials. Certain applications (i.e.
refractories, enamels and coating for casting moulds) make the presence
of zirconium in metallic FCM more likely. A specific example is the use of
zirconium compounds as passivation agents for tin-plated steel.

Other food contact materials

Zirconium (II) is a component of some Ziegler-Natta catalysts, used to
produce polypropylene (Shamiri et al., 2014). Because of its mechanical
strength and flexibility, zirconium dioxide (ZrO2) is used for sintering into
ceramic knives.

Release
The release of zirconium into foodstuffs will potentially depend on the spe-
cific compound and its associated chemical properties, most importantly
solubility. Since no data has been published on the concentrations of zirco-
nium in FCM, the release of zirconium from these materials into foodstuffs
cannot be assessed.

138
Zr
 Zirconium (Zr)

Safety aspects
A maximum limit for zirconium in stainless steel was imposed in France,
stating that zirconium can only make up 1% of the alloy (French Decree of
13 January 1976; JRC, 2016).
In the USA, zirconium oxide is permitted for use in conversion coatings
on the interior of tin-plated steel containers (cans), with or without a pol-
ymeric topcoat. The coating may be applied to the food contact surface at
a maximum coating weight of 9 mg/m2. The finished coating may be in
contact with all food types, with the exception of liquid (concentrate and
ready to feed) infant formula (NLM LCSS; FDA).
The administrative exposure limit (MAC) for zirconium and zirconium
compounds in the Netherlands is 5 mg/m3, 8-hour TWA (time-weighted
average) (Health Council of the Netherlands, 2002).
The route of absorption and excretion has not been established for all zir-
conium compounds and depends on the route and duration of exposure
(Ghosh et al., 1992). Most zirconium compounds are poorly absorbed from
the gastrointestinal tract into the bloodstream. Following oral absorp-
tion, absorption percentages of 0.2 and 0.001% have been reported (Health
Council of the Netherlands, 2002). The predominant excretion route is via
the faeces; very little is excreted in the urine. Tissue levels are generally
below 10 μg/g wet tissue (Health Council of the Netherlands, 2002). Milk
is a second route of excretion. Significant amounts of zirconium have also
been found in foetuses (NLM HSDB).
Regarding the toxicity of zirconium, few animal studies are available and
these show non-uniform results among the different zirconium com-
pounds. In humans, few case reports are available, some of which suggest
toxic effects after exposure to zirconium compounds via different routes
(mostly inhalation); others show no zirconium-related effects (NLM HSDB).
Overall, based on the available literature, no definitive conclusion can be
drawn on the potential for zirconium to produce toxic effects. The Health
Council of the Netherlands concluded in 2002 that the available toxicolog-
ical database on zirconium and its compounds was too poor to justify rec-
ommendation of a health-based occupational limit, including the exposure
limit (MAC) stated in the Netherlands.

139
Zr
 Metals and alloys used in food contact materials and articles

An SML of 2 mg/kg has been established for zirconium used for passiva-
tion of metals and alloys in the Netherlands (Dutch WVG Regulation).
Based on the example material tested in the application dossier, the limit
of 2 mg/kg is fully achievable. Available toxicity studies showed absence of
genotoxic potential, and the overall NOAEL of 41 mg/kg bw/day derived
from a combined repeated dose toxicity study (OECD TG 422) in rats led to
a MOE for the potential exposure from use of zirconium in food contact of
over 1 000, which was considered sufficient.
According to the Dutch WVG Regulation, the following provision is
also applicable: For contact with acidic foods, conformity with this SML
is to be tested in the relevant food product, or alternatively with 1.5%
citric acid. If the properties of acetic acid predominate in the foodstuffs
with which the metal comes into contact, the metal passivated with zir-
conium must be coated with organic polymers. This provision does not
apply to zirconium-passivated metal in contact with non-acidic food or in
contact with food in which the properties of acids other than acetic acid
predominate1.

Conclusions and recommendations

the SRL for zirconium is set at 2 mg/kg food or food simulant

Given the lack of sufficient data available to derive a TDI, the SRL of zir-
conium is set at 2 mg/kg, as in the legislation on FCM in the Netherlands.
For acidic foods, conformity with the SRL should be tested in the relevant
food product, or alternatively with 0.5% citric acid. Zirconium-passivated
metals can be used in direct contact with food where the properties of that
foodstuff are non-acidic or acidic, if the acidic character is derived from an
acid other than acetic acid.

1 The zirconium released forms ZrO2 that is insoluble in 3% acetic acid. Its precipita-
tion results in misleading determination of the release of zirconium (only soluble
part in the supernatant) while formation of nanoparticles cannot be excluded. Anal-
ogous precipitation does not take place in citric acid. Summary Data Sheet on Zirco-
nium. Dutch G4-commission. 2014 and amended in 2021 (unpublished).

140
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 Zirconium (Zr)

References
Arrêté du 13 janvier 1976. Matériaux et objets en acier inoxydable au contact des denrées ali-
mentaires [Decree of 13 January 1976. Stainless steel materials and articles in contact with
foodstuffs]. Journal officiel de la République française 31 janvier 1976 [available at https ://
www.legifrance.gouv.fr/jorf/id/JORFTEXT000000637961, accessed 22 Nov 2022].
Dutch Minister for Public Health, Welfare and Sport. Warenwetregeling verpakkingen en
gebruiksartikelen (WVG), Bijlage Deel A, Hoofdstuk IV – Metalen [Commodities Act Reg-
ulation on packagings and consumer articles coming into contact with foodstuffs, Annex
Part A, Chapter IV – Metals]. 2022 [available at https://wetten.overheid.nl/BWBR0034991,
accessed 25 Nov 2022].
US Food & Drug Administration (FDA). Zirconium oxide. Inventory of Food Contact Sub-
stances Listed in 21 CFR. [Available at https://www.accessdata.fda.gov/scripts/fdcc/index.
cfm?set=IndirectAdditives&id=ZIRCONIUMOXIDE, accessed 20 Sep 2021].
Ghosh S, Sharma A, Talukder G. Zirconium. An abnormal trace element in biology. Biol
Trace Elem Res 1992;35(3):247-71. https://doi.org/10.1007/BF02783770.
Health Council of the Netherlands (Gezondheidsraad). Zirconium and zirconium com-
pounds (CAS No: 7440-67-7). Health-based Reassessment of Administrative Occupa-
tional Exposure Limits; No 2000/15OSH/059; 31 October 2002 [available at https://www.
healthcouncil.nl/documents/advisory-reports/2002/10/31/zirconium-and-zirconium-
compounds, accessed 25 Nov 2022].
International Labour Organization (ILO). Zirconium and Hafnium. Encyclopaedia of
Occupational Health & Safety. 2011 [available at https://www.iloencyclopaedia.org/part-
ix-21851/metals-chemical-properties-and-toxicity/item/198-zirconium-and-hafnium,
accessed 20 Sep 2021].
EC JRC. Non-harmonised food contact materials in the EU: regulatory and market sit-
uation. 2016 [available at http://publications.jrc.ec.europa.eu/repository/bitstream/
JRC104198/en_jrc104198_fcm%20baseline%20final%20report%202017-01-16_all.pdf,
accessed 25 Nov 2022].
National Library of Medicine Hazardous Substances Data Bank (NLM HSDB). Zirconium
compounds. [Available at https://pubchem.ncbi.nlm.nih.gov/source/hsdb/7347, accessed
21 Oct 2021].
National Library of Medicine Laboratory Chemical Safety Summary (NLM LCSS) Data-
sheet. Zirconium dioxide. CID 62395. [Available at https://pubchem.ncbi.nlm.nih.gov/
compound/62395, accessed 20 Sep 2021].
Organisation for Economic Cooperation and Development (OECD). Test No 422: Com-
bined Repeated Dose Toxicity Study with the Reproduction/Developmental Toxicity
Screening Test. https://doi.org/10.1787/9789264264403-en.
Peterson J, MacDonell M, Haroun L, et al. Zirconium. Radiological and Chemical Fact
Sheets to Support Health Risk Analyses for Contaminated Areas. Argonne National

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 Metals and alloys used in food contact materials and articles

Laboratory. 2007:64-5 [available at https://web.archive.org/web/20080528130257/http:/

www.evs.anl.gov/pub/doc/ANL_ContaminantFactSheets_All_070418.pdf, accessed
25 Nov 2022].
Shamiri A, Chakrabarti MH, Jahan S, et al. The Influence of Ziegler-Natta and Metal-
locene Catalysts on Polyolefin Structure, Properties, and Processing Ability. Materials
(Basel) 2014;7(7):5069-108. https://doi.org/10.3390/ma7075069.

142
Zr
Metal contaminants and impurities

The following metals are relevant contaminants and impurities that may
occur in FCM and articles.
Arsenic (As)
Barium (Ba)
Beryllium (Be)
Cadmium (Cd)
Lead (Pb)
Lithium (Li)
Mercury (Hg)
Thallium (Tl)

143
 As
Arsenic (As)

Arsenic is the 54th most abundant element in the

Earth’s crust, which contains 1.8 mg/kg of arsenic
down to a depth of 16 km.
It is a notoriously toxic metalloid that has numerous
allotropic forms: yellow (non-metallic allotrope);
several black and grey (metalloids). Several hundreds
of these mineral species are known.
Arsenic and its compounds are used as pesticides,
herbicides and insecticides.
The arsenic content of some iron ores is similar
to their phosphorus content. Both substances
enter the steel production as impurities from raw
materials and/or processing contaminants and
may adversely affect steel quality. The presence
of arsenic reduces the impact strength of steel.

Sources and levels of intake

Seafood and fish are foodstuffs rich in arsenic. Many types of vegetable also
contain arsenic (e.g. cabbage and spinach) (Arnich et al., 2012; Guéguen et
al., 2011; Schoof et al., 1999). It is also found in some sources of drinking
water.
Making a number of assumptions for the contribution of inorganic arsenic
to total arsenic, the inorganic arsenic exposure from food and water across
19 European countries, using LB and UB concentrations, has been esti-
mated to range from 0.13 to 0.56 μg/kg bw/day for average consumers, and
from 0.37 to 1.22 μg/kg bw/day for 95th percentile consumers. Dietary expo-
sure to inorganic arsenic for children under 3 years of age is in general

145
As
Metals and alloys used in food contact materials and articles

estimated to be from 2 to 3-fold that of adults (EFSA, 2009). ANSES (2011)

estimated mean daily intake of inorganic arsenic at 0.28 µg/kg bw/day in
adults and 0.39 µg/kg bw/day in children (according to UB concentrations).

Metallic food contact materials

Some of the less common food contact alloys can contain arsenic. Special
types of brass are obtained by incorporating one or more additional ele-
ments such as tin, aluminium, manganese, nickel, iron, silicon or even
arsenic, which improves some of their properties, particularly their
mechanical characteristics, mostly to increase their resistance to corrosion.
In France, tin or tin alloys and articles exclusively coated with tin or tin
alloy or partly tin-plated, which as finished products are designed to come
into direct, recurrent contact with foodstuffs, must not exceed a maximum
arsenic content of 0.030% (French Decree of 28 June 1912).

Other food contact materials

Arsenic is used in the processing of the following products: glass, pigments,
textiles, paper, metal adhesives, ceramics and wood conservation agents.
Orpiment is an arsenic sulfide mineral found naturally or produced artifi-
cially. It is also known as yellow arsenic. It has a fine, golden yellow colour
and has been known since the second millennium BC. Its use as a pigment
was abandoned after the arrival of cadmium pigments in the 19th century.

Release
No information available.

Safety aspects
• WHO (2022) established a provisional guideline value for arsenic in
drinking water of 0.01 mg/L on the basis of treatment performance and
analytical achievability.

146
 As
Arsenic (As)

• The JECFA PTWI of 15 μg/kg bw/week (2.1 μg/kg bw/day) for arsenic was
set in 1988 (JECFA, 1989). In 2010, at the 72nd JECFA meeting, arsenic
was reassessed and a BMD approach was used to assess the epidemio-
logical data available. The inorganic arsenic lower limit of the BMD for
a 0.5% increased incidence of lung cancer (BMDL05) was determined
from epidemiological studies to be 3.0 μg/kg bw/day (2-7 μg/kg bw/day
based on the range of estimated total dietary exposure) using a range of
assumptions to estimate total dietary exposure to inorganic arsenic from
drinking water and food. As the previous PTWI (JECFA, 1989) is within
this range, it was no longer considered appropriate and it has since been
withdrawn (JECFA, 2010).
• In their 2008 statement, the COT considered that inorganic arsenic is
genotoxic and a known human carcinogen and, therefore, exposure
should be as low as reasonably practicable.
• EFSA (2009) used a BMD approach to assess arsenic, using data from
key epidemiological studies and noting other modelling results. A bench-
mark response of 1% extra risk was selected and the range of the 95%
lower confidence interval of the dose (BMDL01) causing this response was
considered. Lung cancer had the lowest BMDL01, with an overall range of
0.3-8.0 µg/kg bw/day. There is little or no MOE between estimated dietary
exposure and this range and therefore the possibility of a risk to consum-
ers cannot be excluded.
• In a 2016 assessment of exposure to arsenic in infants (0-1 years) and
young children (1-5 years), the COT concluded that total exposure to
inorganic arsenic, from dietary and non-dietary sources generally leads
to MOEs of significantly less than 10 and could therefore pose a risk to
health. When comparing the estimated exposures from different sources,
it becomes apparent that in these age groups, dietary sources generally
contribute more significantly to exposure than non-dietary sources such
as soil and dust. It is therefore reiterated that efforts to reduce the levels
of inorganic arsenic in food and water should continue.
• The COT also concluded (2018) that dietary exposure to organic arsenic is
unlikely to constitute a risk to health.

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Metals and alloys used in food contact materials and articles

Conclusions and recommendations

the SRL for arsenic is set at 0.002 mg/kg food or food simulant

Arsenic can be found in the form of impurities in many metals and alloys.
Efforts are therefore needed to prevent its possible release.
In light of the EFSA, JECFA and COT assessments (COT, 2016; EFSA, 2009;
JECFA, 2010), using the JECFA (1989) PTWI as a basis for deriving an SRL
was not considered appropriate. Instead, the lower end of the BMDL01 from
the EFSA (2009) assessment was used, resulting in a limit of 0.0003 mg/kg
bw/day (0.018 mg/day). As arsenic is considered an impurity in the metallic
material, it was concluded that an allowance of 10% of the TRV was reason-
able. Therefore, assuming a person of 60 kg bw consumes 1 kg of foodstuffs
per day that is packaged and/or prepared with FCM made from metals and
alloys, the SRL for arsenic is set at 0.002 mg/kg.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Arnich N, Sirot V, Rivière G, et al. Dietary exposure to trace elements and health risk
assessment in the 2nd French Total Diet Study. Food Chem Toxicol 2012;50(7):2432-49.
https://doi.org/10.1016/j.fct.2012.04.016.
Arrêté du 28 juin 1912. La coloration, la conservation et l’emballage des denrées alimen-
taires [French decree of 28 June 1912 on Colouring, preservation and packaging of food-
stuffs]. 1912 [available at https://www.legifrance.gouv.fr/loda/id/LEGITEXT000006071519,
accessed 25 Nov 2022].
COT. Statement on the 2006 UK Total Diet Study of Metals and Other Elements. Decem-
ber 2008 [available at https://cot.food.gov.uk/sites/default/files/cot/cotstatementtds200808.
pdf, accessed 21 Nov 2022].
COT. Statement on potential risks from arsenic in the diet of infants aged 0 to 12 months
and children aged 1 to 5 years. 2016 [available at https://webarchive.nationalarchives.gov.
uk/ukgwa/20200808010226/https://cot.food.gov.uk/cotstatements/cotstatementsyrs/cot-
statements-2016/statement-on-potential-risks-from-arsenic-in-the-diet-of-infants-aged-
0-to-12-months-and-children-aged-1-to-5-years, accessed 25 Nov 2022].
COT. Statement on the results of the 2014 survey of metals and other elements in infant foods.
2018 [available at https://webarchive.nationalarchives.gov.uk/ukgwa/20200808010105/

148
 As
Arsenic (As)

https://cot.food.gov.uk/cotstatements/cotstatementsyrs/cot-statements-2018/statement-
on-the-results-of-the-2014-survey-of-metals-and-other-elements-in-infant-foods,
accessed 25 Nov 2022].
EFSA. Scientific Opinion on Arsenic in Food. EFSA Journal 2009 ;7(10) :1351. https://doi.
org/10.2903/j.efsa.2009.1351.
Guéguen M, Amiard JC, Arnich N, et al. Shellfish and residual chemical contaminants:
hazards, monitoring, and health risk assessment along French coasts. Rev Environ Contam
Toxicol. 2011;213:55-111. https://doi.org/10.1007/978-1-4419-9860-6_3.
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 776. 1989 [available at https://apps.who.int/iris/handle/10665/39252, accessed
17 Nov 2022].
JECFA. Evaluation of certain food contaminants. WHO Technical Report Series 959. 2010
[available at https://apps.who.int/iris/handle/10665/44514, accessed 17 Nov 2022].
Schoof RA, Yost LJ, Eickoff J, et al. A market basket survey of inorganic food. Food Chem
Technol 1999;37(8):839-46. https://doi.org/10.1016/s0278-6915(99)00073-3.
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

149
 Ba
Barium (Ba)

The mineral barite (or barytine) is the raw material

from which virtually all barium compounds
are derived. World production of barite in 1985
was estimated at 5.7 million tonnes (WHO, 1990).
Estimates of barite global production are available
on the internet and place 2022 figures in the region
of 7.9 million metric tons (Garside, 2023). Barium
and its compounds are used in various industrial
products, ranging from ceramics to lubricants. It is
also used in the manufacture of alloys, as a weighting
element for paper, soap, rubber and linoleum, and
in the manufacture of valves (WHO, 1990).

Sources and levels of intake

The main sources of barium in the human diet are milk, potatoes and
flour. Some cereal products and nuts tend to have high barium content, e.g.
groundnuts, bran flakes and Brazil nuts (WHO, 1990). Some plant species
accumulate barium when they grow in a soil rich in this element (WHO,
1990).
ANSES (2011) estimated mean daily intake at 0.38 mg/day (6.4 µg/kg bw/day)
in adults and 10.2 µg/kg bw/day in children.
Health Canada (2020) recommends a maximum acceptable concentra-
tion (MAC) for total barium in drinking water of 2.0 mg/L (2 000 µg/L).
They estimate the average intake of barium from drinking water at 2 µg/kg
bw/day (rounded) for an adult of 74 kg and a consumption of 1.53L/d water.

151
 Metals and alloys used in food contact materials and articles
Ba

In the UK Total Diet Study, the highest total mean and 97.5th percentile
exposures were in the 1.5 to 3 years age class and were 20 μg/kg bw/day and
33 μg/kg bw/day, respectively (FSA, 2014).

Metallic food contact materials

Barium is to be found in certain metals and alloys in the form of impurities.
Barium reacts strongly with metals to form metal alloys. Iron is the most
resistant metal to barium. Barium forms inter-metallic compounds and
alloys with lead, potassium, platinum, magnesium, silicon, zinc, alumin-
ium and mercury (Hansen, 1958). Metallic barium reduces oxides, halides,
sulfides and most of the less reactive metals to their elemental state. It is
therefore used in molten salt baths for thermal treatment of metals. Metal
bromates [Ba(BrO3)2] are used for preparing rare-earth bromates and
inhibiting corrosion in low-carbon steels. It is used in aluminium refining.
The chromate (BaCrO4) is an anti-corrosion pigment for metals.

Other food contact materials

Besides the use of barium and barium compounds in ceramics, the chloride,
BaCl2, is used in the pigment, lacquer and glass industries. In the dyeing
industry, it is used as a mordant and load, as well as in dyeing textile fibres.
The chromate, BaCrO4, is also used to colour glass, ceramics and porcelain.

Release
No information available.

Safety aspects
• The EPA (1985) derived an RfD of 0.2 mg/kg/day. In 2005 the EPA
reassessed barium and confirmed the RfD for barium of 0.2 mg/kg
bw/day. However, new studies were taken into consideration and a BMDL
approach was chosen. Consequently, the RfD was derived from a BMDL5
of 63 mg/kg bw/day for a 5% increased risk of nephropathy in mice with

152
 Barium (Ba)

Ba
an uncertainty factor of 300 (100 for intra- and interspecies variability
and 3 for database deficiencies).
• WHO (2001) specified a TDI of 0.02 mg/kg bw/day (1.2 mg/day) from an
epidemiological study. In that study, populations from two cities with a
70-fold difference in drinking water concentrations of barium were inves-
tigated. Significant differences in cardiovascular effects, however, could
not be detected. Using the higher barium drinking water concentration
of the two cities, a TDI of 0.21 mg/kg bw/day was derived and divided by
an uncertainty factor of 10 to account for database deficiencies and possi-
ble differences between adults and children.
• WHO (2022) established a guideline value for barium in drinking water
of 1.3 mg/L.
• In their 2008 statement, the COT considered that since the WHO TDI
was based on studies that did not show statistically significant effects, it
was possible that the LOAEL could be much higher than the NOAEL and
therefore the TDI could be over-precautionary. The COT concluded that
exposures of up to 4-fold above the TDI were not necessarily a toxicolog-
ical concern.

Conclusions and recommendations

the SRL for barium is set at 1.2 mg/kg food or food simulant

It was decided to use the EPA RfD of 0.2 mg/kg bw/day (12 mg/day) to
derive the SRL. As barium is considered an impurity in the metallic mate-
rial, it was concluded that an allowance of 10% of the TRV was reasonable.
Therefore, assuming that a person of 60 kg bw consumes 1 kg of foodstuffs
per day that is packaged and/or prepared with FCM made from metals and
alloys, the SRL for barium is set at 1.2 mg/kg.

References
ANSES. Second French Total Diet Study (TDS 2) – Report 1 – Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].

153
 Metals and alloys used in food contact materials and articles
Ba

COT. Statement on the 2006 UK Total Diet Study of Metals and Other Elements. Decem-
ber 2008 [available at https://cot.food.gov.uk/sites/default/files/cot/cotstatementtds200808.
pdf, accessed 21 Nov 2022].
EPA. Barium: health advisory. 1985 [available at https://nepis.epa.gov/Exe/ZyNET.
exe/94006C0D.txt?ZyActionD=ZyDocument&Client=EPA&Index=1986%20Thru%20
1990&Docs=&Query=&Time=&EndTime, accessed 25 Nov 2022].
EPA. Toxicological Review of Barium and Compounds (CAS No 7440-39-3). 2005 [avail-
able at https://cfpub.epa.gov/ncea/iris/iris_documents/documents/toxreviews/0010tr.pdf,
accessed 25 Nov 2022].
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/research/research-projects/
total-diet-study-metals-and-other-elements, accessed 17 Nov 2022].
Garside M. Global barite production volume 2011 to 2022. 3 Mar 2023 [available at https://
www.statista.com/statistics/799487/global-barite-production, accessed 5 Jul 2023].
Hansen M. Constitution of binary alloys. New York: McGraw-Hill Book Company, Inc.;
1958.
Health Canada. Guidelines for Canadian Drinking Water Quality: Guideline Tech-
nical Document – Barium. 2020 [available at https://tinyurl.com/mtvza8s3, accessed
25 Nov 2022].
WHO IPCS. Barium. Environmental Health Criteria 107. 1990 [available at https://inchem.
org/documents/ehc/ehc/ehc107.htm, accessed 25 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

154
 Beryllium (Be)

Be
Beryllium has the highest melting point of all the
light metals. It is lighter and six times more resilient
than aluminium. It is approximately 1⅓ times more
ductile than steel. It is an excellent heat conductor,
is non-magnetic and is resistant to concentrated
nitric acid. Under normal conditions of temperature
and pressure beryllium is oxidation-resistant when
exposed to air. A thin layer of oxide is formed, making
it hard enough to scratch glass.
In nature, it is mainly found in the form of oxides or
complex beryllium-aluminium-silicates known as
beryls, the best-known gemstone variants of which are
emeralds and aquamarines. In view of the scarcity of
beryllium in nature (3 mg/kg), it raises no particular
environmental concerns, but its industrial use in coal
mining, aeronautics and the nuclear arms industry
leads to its dispersal in the air and its deposition in
the environment, contaminating water, soil, air and
the human body (Mroz et al., 2001). There is also
controversy about its use in dentistry, for dental
prostheses (Mroz et al., 2001).
It is mainly used as a hardening agent in alloys such
as moldamax, a copper-beryllium alloy used for
manufacturing moulds for plastics.
Its alloys are light, rigid, heat-resistant and have a
low dilation coefficient. It is incorporated into some
special alloys, e.g. materials used for friction.

155
 Metals and alloys used in food contact materials and articles

Sources and levels of intake

The intake in the USA, as estimated by the EPA (1987, 1998), is 0.42 µg/day
Be

via water and food (0.12 µg/day from food and 0.3 µg/day from water).
Much of the intake is, therefore, deemed to come from drinking water. On
the other hand, WHO (2022) states that beryllium is unlikely to occur in
drinking water and consequently, it has been ‘excluded from guideline
value derivation’. Results from a duplicate diet study in Spain estimated the
dietary intake of beryllium equal to 19 µg/day (Domingo et al., 2012).

Metallic food contact materials

Beryllium can be found in the form of impurities in some metals and alloys,
though seldom as an alloy component. Although beryllium is theoreti-
cally highly unlikely to come into contact with food, its use in plumbing,
boiler-making and piping cannot be precluded.

Other food contact materials

Beryllium oxide can potentially be used in the ceramics industry, but there
is no evidence of it being used for ceramics coming into contact with food.

Release
No information available.

Safety aspects
• The EPA (1998) recommended an RfD of 0.002 mg/kg bw/day (i.e.
0.12 mg/day for a person weighing 60 kg) for beryllium. In 1987, the EPA
estimated beryllium intake in the USA at 0.423 µg/day via water and food,
which is negligible compared to the RfD.
• WHO (1990; 2001) shows that there is little data available on oral tox-
icity of beryllium. The bulk of the information available pertains
to inhalation toxicity and, in particular, the effects of inhalation in

156
 Beryllium (Be)

occupationally-exposed workers. WHO (2001) derived an oral tolerable

intake of 0.002 mg/kg bw/day. This value was estimated using the BMD10
of 0.46 mg/kg bw/day at the lower 95% confidence limit for a 10% inci-

Be
dence of small intestinal lesions in dogs chronically exposed to beryllium
sulfate tetrahydrate and considered equal to the NOAEL. In addition, an
uncertainty factor of 300 (10 for interspecies, 10 for intraspecies variation
and 3 for database deficiencies due to a lack of data on developmental
effects or mechanistic data, suggesting this may be an issue) was applied.

Conclusions and recommendations

the SRL for beryllium is set at 0.01 mg/kg food or food simulant

The proven high toxicity of beryllium means that any potential release must
be limited.
The SRL for beryllium was derived on the basis of the oral tolerable intake
of 0.002 mg/kg bw/day (0.12 mg/day) (WHO, 2001). As beryllium is consid-
ered an impurity in the metallic material, it was concluded that an allow-
ance of 10% of the TRV was reasonable. Therefore, assuming that a person
of 60 kg bw consumes 1 kg of foodstuffs per day that is packaged and/or
prepared with FCM made from metals and alloys, the SRL for beryllium is
set at 0.01 mg/kg.

References
Domingo JL, Perelló G, Giné Bordonaba J. Dietary intake of metals by the population of
Tarragona County (Catalonia, Spain): results from a duplicate diet study. Biol Trace Elem
Res 2012;146(3):420-5. https://doi.org/10.1007/s12011-011-9269-5.
EPA. Health Assessment Document for Beryllium. EPA/600/8-84/026F; 1987 [availa-
ble at https://oehha.ca.gov/media/downloads/proposition-65/chemicals/beryllium.pdf.
Accessed 25 Nov 2022].
EPA. Toxicological review of Beryllium and compounds. EPA/635/R-98/008; 1998 [avail-
able at https://cfpub.epa.gov/ncea/iris/iris_documents/documents/toxreviews/0012tr.pdf,
accessed 25 Nov 2022].
Mroz MM, Balkissoon R, Newman LS. Beryllium. In: Bingham E, Cohrssen B, Powell
C, editors. Patty’s Toxicology, Fifth Edition. New York: John Wiley & Sons; 2001: 177-220.

157
 Metals and alloys used in food contact materials and articles

WHO IPCS. Beryllium. Environmental Health Criteria 106. 1990 [available at https://
inchem.org/documents/ehc/ehc/ehc106.htm, accessed 25 Nov 2022].
WHO IPCS. Beryllium and beryllium compounds. Concise International Chemical
Be

Assessment Document 32. 2001 [available at https://inchem.org/documents/cicads/cicads/

cicad32.htm, accessed 25 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

158
 Cadmium (Cd)

Cd
Cadmium is one of the metallic elements of most
concern in the food and environment of man. It
is widely distributed, occurring in all soils and
rocks, including coal, in very low concentrations
(<0.1 mg/kg) (ATSDR, 2012; Lind, 1997). Cadmium
occurs with zinc and lead in sulfide ores (Nordberg
et al., 2022). Cadmium is released to the air, land and
water by human activities (WHO, 1992). Increases
in soil cadmium content result in an increase in the
uptake of cadmium by plants. The application of
phosphate fertilisers and atmospheric deposition
are significant sources of cadmium input to arable
soils in some parts of the world; sewage sludge
can also be an important source at the local level
(WHO, 1992). Cadmium metal was previously used
as an anti-corrosive when electroplated onto steel
(Nordberg et al., 2022). Cadmium can be replaced by
other less toxic materials, for instance in batteries.

Sources and levels of intake

Cadmium is found in most foodstuffs in the range of 0.005-0.1 mg/kg
(Nordberg et al., 2022). Certain foodstuffs, e.g. kidneys and oysters, may
contain much higher concentrations (Nordberg et al., 2022). The lowest
levels of cadmium are found in dairy products and beverages (EC, 2004).
Vegetables, cereals and cereal products contribute most to cadmium intakes.
The mean dietary exposure across European countries was calculated to
be 2.3 μg/kg bw/week and the high exposure was calculated to be 3.0 μg/kg

159
 Metals and alloys used in food contact materials and articles

bw/week. Due to their high consumption of cereals, nuts, oilseeds and

pulses, vegetarians have a greater dietary exposure of up to 5.4 μg/kg
bw/week. Regular consumers of bivalve molluscs and wild mushrooms
were also found to have higher dietary exposures of 4.6 and 4.3 μg/kg
bw/week, respectively (EFSA, 2009). ANSES (2011) estimated mean daily
Cd

intake at 1.12 µg/kg bw/week in adults and 1.68 µg/kg bw/week in children.
Tobacco smoking can contribute to a similar internal exposure as that from
the diet. House dust can be an important source of exposure for children
(EFSA, 2009).

Metallic food contact materials

The use of cadmium-plated equipment and machinery in food produc-
tion is forbidden according to Regulation (EC) No 1907/2006 (REACH).
Cadmium can occur as an impurity in zinc galvanised pipes and in solders
in fittings, water heaters, water coolers, and taps (Nordberg et al., 2022).

Other food contact materials

Historically, cadmium sulfide and cadmium selenide have been used as
red, yellow and orange colour pigments in plastics and various types of
paint (Nordberg et al., 2022). Cadmium stearate was previously used as a
stabiliser in plastics (Nordberg et al., 2022). Cadmium can still be used as a
pigment in certain enamels in FCM. Leachable cadmium in enamel pottery
and glazes may be a source of food contamination.

Release
The release information on cadmium is limited. Cadmium, like zinc, loses
its lustre in moist air and is rapidly corroded by moist NH3 and SO2. It is
readily attacked by most acids, but more slowly than zinc (Beliles, 1994).
One study could be identified where the release of cadmium from pewter
cups was investigated. Using different beverages (e.g. wine, beer) and sim-
ulants (e.g. vinegar, 3% acetic acid), a release of cadmium ranging from
< LOD (beer) to 8.2 µg/L (3% acetic acid) was measured (Dessuy et al., 2011).

160
 Cadmium (Cd)

Safety aspects
• JECFA (1993) established a PTWI of 0.007 mg/kg bw/week, stating that
‘the PTWI does not include a safety factor’ and that ‘there is only a rel-
atively small safety margin between exposure in the normal diet and
exposure that produces deleterious effects’. This value was confirmed by

Cd
JECFA in 2003. During their 73rd meeting in 2010, JECFA withdrew the
PTWI of 0.007 mg/kg bw/week and replaced it by a PTMI of 0.025 mg/kg
bw/month, due to the exceptionally long half-life of cadmium (JECFA,
2010).
• WHO (2022) established a guideline value for cadmium in drinking water
of 0.003 mg/L.
• In the EU the limit for cadmium in drinking water has been set to
0.005 mg/L (Directive (EU) 2020/2184).
• Cadmium is unique among the metals because of its combination of tox-
icity in low dosages, long biological half-life (about 30 years in humans),
its low rate of excretion from the body, and the fact that it is stored pre-
dominantly in the soft tissues (liver and kidney) (Beliles, 1994). The
PTWI is based upon kidney damage and the long half-life of cadmium.
The effects of cadmium on humans are nephrotoxicity, osteotoxicity,
cardiovascular-toxicity, genotoxicity and effects on reproduction and
development (EFSA, 2009). Kidney damage also occurs as a result of
cadmium exposure (Beliles, 1994). Occasional peaks in cadmium intake
may cause a drastic increase in fractional absorption of cadmium (Lind,
1997). Ingestion of highly contaminated foodstuffs or drinks results
in acute gastrointestinal effects in the form of diarrhoea and vomit-
ing (Nordberg et al., 2022). About 5% of ingested cadmium is absorbed
(Nordberg et al., 2022). The speciation of cadmium in foodstuffs may be of
importance for the evaluation of the health hazards associated with areas
of cadmium contamination or high cadmium intake (WHO, 1992). The
bioavailability of cadmium differs depending on the form of cadmium
present. For instance, cadmium of animal origin has been shown to have
a lower bioavailability in mice than cadmium of vegetable origin (Lind,
1997). Cooking does not seem to alter the bioavailability of cadmium of
animal origin.

161
 Metals and alloys used in food contact materials and articles

• EFSA (2009) has derived a TWI for cadmium of 0.0025 mg/kg bw/week.
This TWI was derived from dose-response data between urinary cadmium
concentrations and urinary beta-2-microglobulin (B2M), a marker for
tubular effects in kidneys. Using the BMDL for a 5% increase in the prev-
alence of elevated B2M (BMDL5) resulted in a limit of 1 μg Cd/g creati-
Cd

nine. Subsequently, the dietary cadmium intake that corresponds to a

concentration below 1 μg Cd/g creatinine in the urine was estimated from
exposure data, resulting in the above TWI.

Conclusions and recommendations

the SRL for cadmium is set at 0.005 mg/kg food or food simulant

The use of cadmium in metals and alloys in materials in contact with food-
stuffs is unacceptable due to its long biological half-life (about 30 years in
humans) and its high toxicity.
Electroplated equipment should be coated.
The SRL was derived from the EFSA (2009) assessment, rather than from
that of JECFA (2010), because it resulted in a more conservative limit. Using
the EFSA (2009) TWI of 0.0025 mg/kg bw/week as a starting point resulted
in a TDI of 0.00036 mg/kg bw/day (0.02 mg/person/day). Using an allow-
ance of 10% of the TRV and assuming that a person of 60 kg bw consumes
1 kg of foodstuffs per day that is packaged and/or prepared with FCM
made from metals and alloys, the calculated limit for cadmium would be
0.002 mg/kg.
However, it was decided to set the SRL at 0.005 mg/kg, which is consistent
with the limit for cadmium stated in Directive (EU) 2020/2184. This equals
an allowance of 25% of the TRV.

References
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https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].

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ATSDR. Toxicological profile for cadmium. US Department of Health and Human Services.
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and Toxins in Food and Feed. CXS 193-1995. Adopted 1995; Revised 1997, 2006, 2008,

Cd
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01 July 2023].

164
 Lead (Pb)

Lead is found as a contaminant in air, water and

Pb
soils. The Earth’s crust contains about 15 mg/kg of
lead (Beliles, 1994). Lead is present in the environment
in the form of metallic lead, inorganic ions and salts
and organo-metallic compounds. There are numerous
sources of contamination, including accumulators,
petrol, manufacturing or recycling of lead batteries
and combustion of industrial and household waste.
Lead pollution is decreasing in most parts of the
world, as lead-containing chemicals, such as tetraethyl
lead and tetramethyl lead that were used as gasoline
additives to increase octane rating, have been replaced
by other additives (ATSDR, 2020). Exposure through
drinking water, where lead or lead-soldered pipes
are still used, may contribute significantly to lead
intake. The greatest single use of lead metal today is in
batteries for automobiles (Beliles, 1994). Most of the
lead in the environment is present as complex bound
lead ions in solution or as slightly soluble Pb(II) salts.

Sources and levels of intake

Lead in the soil is only poorly taken up by plant roots and is not trans-
ported away from the roots to the rest of the plant. Therefore, lead levels
in plants are, to a large extent, governed by air-borne lead contamination,
which makes leaves and leafy vegetables most vulnerable to air-borne dep-
osition (EFSA, 2010). Cereal grains have also been shown to absorb compar-
atively large amounts of lead via the air (CCFAC, 1995). The main sources
of lead intake are foodstuffs such as vegetables, cereals and cereal products

165
 Metals and alloys used in food contact materials and articles

and drinking water/materials in contact with drinking water (EFSA, 2010).

Game and shellfish may also contain rather high amounts of lead (EFSA,
2010).
In Europe, lead dietary exposure ranges from 0.36 to 1.24 μg/kg bw/day in
average adult consumers and up to 2.43 μg/kg bw/day in high consumers.
Exposure of infants ranges from 0.21 to 0.94 μg/kg bw/day and of children
from 0.80 to 3.10 μg/kg bw/day (average consumers) and up to 5.51 μg/kg
bw/day (high consumers) (EFSA, 2010). ANSES (2011) estimated mean daily
Pb

intake at 0.20 μg/kg bw/day in adults and 0.27 μg/kg bw/day in children.
Additionally, dust and soil can be significant non-dietary sources in chil-
dren (EFSA, 2010).

Metallic food contact materials

Canned foodstuffs used to contribute to the general intake of lead, but
lead-soldering of tin cans is less common today (Bergdahl and Skerfving,
2022). Metallic lead in food is likely to arise from the presence of lead from
shot or partially-jacketed bullets in game. Lead is also found in the lead
solder used to repair equipment. Manufacturing equipment and household
utensils may contain lead, that may be released when in contact with food.
Lead pipes or lead solder used to repair equipment have also caused contam-
ination problems. The lead that may be found as a contaminant in pewter
may also be released. Tin is also liable to release lead due to its presence in
the metal as an impurity; the standard specification of Ingot tin (according
to European Standard EN 610:1995) specifies a maximum permissible lead
content of 0.050% and the standard specification of tinplate (according to
European Standard EN 10333:2005) specifies a maximum permissible lead
content of 0.01%. The EU Packaging Waste Directive (94/62/EC) limits the
lead content of tin cans to less than 100 ppm.

Other food contact materials

Previously, lead pigments were often used in ceramic glazes (Beliles, 1994).
However, because lead pigments are toxic, their use is now restricted. In the
EU, lead release is currently regulated by Directive 84/500/EEC that sets

166
 Lead (Pb)

limits for the release of lead from materials and articles made of ceramics.
Imported products from some countries and handicrafts still need par-
ticular attention. White lead is the most important lead pigment (Beliles,
1994). Lead may still be used as an alloying element in copper and in steel
(for machining purposes, according to Directive 2011/65/EU). In addition,
crystal glass may contain more than 24% lead, in which case it is specifi-
cally named lead crystal glass (Directive 69/493/EEC).

Pb
Release
The information on release of lead from metallic FCM is limited. One study
investigated the release of lead from pewter cups. Using different bever-
ages (e.g. wine, beer) and simulants (e.g. vinegar, 3% acetic acid), the lead
release ranged from < LOD (beer) to 1.1 mg/L (3% acetic acid) after 24 hours’
contact time (Dessuy et al., 2011). A survey with teapots made out of brass
found lead release between 1.1 mg/L and 62 mg/L, using citric acid solution
(1 g/L) as a simulant and a contact time of 30 minutes (Bolle et al., 2011).
A minor source of lead in food cans exists in the form of small impurity
levels in the tin of the coating. Most foodstuffs, those based on citric acid,
will dissolve only a small amount of it. Only foodstuffs based on malic acid
and in cans without an internal lacquer will show a significant tendency to
attack the lead (Bird et al., 1986).

Safety aspects
• JECFA (1993) established a PTWI of 0.025 mg/kg bw/week or
0.214 mg/day/person (average bw ~60 kg). This limit was confirmed by
JECFA in 2000. During their 73rd meeting in 2010, JECFA withdrew the
PTWI, concluding that it could no longer be considered protective of
health. In children, the level of 1.9 μg/kg bw/day was associated with a
decrease of 3 intelligence quotient (IQ) points, which is deemed by the
Committee to be of concern.
• WHO (2022) established a provisional guideline value for lead in drinking
water of 0.01 mg/L, on the basis of treatment performance and analytical

167
 Metals and alloys used in food contact materials and articles

achievability. As this is no longer a health-based guideline value, concen-

trations should be maintained as low as reasonably practical.
• In the EU, the limit for lead in drinking water has been set at 0.005 mg/L
(Directive (EU) 2020/2184). The parametric value of 0.005 mg/L shall be
met, at the latest, by 12 January 2036. The parametric value for lead until
that date shall be 0.010 mg/L.
• For the general population, exposure to lead occurs primarily via the oral
Pb

route, with some contribution through inhalation (EFSA, 2010). In adults,

approximately 15-20% of the ingested lead is absorbed in the gastrointes-
tinal tract (EFSA, 2010). Children, however, seem to show higher absorp-
tion rates (EFSA, 2010). Lead has a half-life in the blood of about a month,
whereas it may have a half-life as long as 30 years in bones (EFSA, 2010).
The toxicity of lead is based on its ability to bind biologically important
molecules and thus to interfere with their function (EFSA, 2010). The
most common form of acute lead poisoning is gastrointestinal colic
(Beliles, 1994). Dietary lead exposure is unlikely to represent a significant
cancer risk (EFSA, 2010).
• It should be noted that the most critical effect of lead on children has
been identified as reduced cognitive development and intellectual perfor-
mance. There is no evidence of a threshold for this effect. This issue was
discussed in a JECFA paper on maximum levels for lead in fish (JECFA,
2006).
• In their 2008 statement, the COT considered that the JECFA PTWI could
not be considered fully protective for all age groups and that, since it is not
possible to identify a threshold for the association between lead exposure
and decrements in IQ, efforts should continue to reduce lead exposure
from all sources. The COT also looked at this for their infant diet work,
concluding that ‘calculated MOEs for dietary exposures in infants were
generally > 1, indicating that at most, any risk from this source of expo-
sure is likely to be small. When allowance is made for the uncertainties,
it appears that total exposure to lead is unlikely to pose a material risk to
health in the large majority of UK infants’ (COT, 2013). However, there
remains a concern that adverse effects could occur where concentrations

168
 Lead (Pb)

of lead in water or soil are unusually high. In 2022, the COT started to
discuss lead in maternal diet.
• In 2010, EFSA published an opinion on lead using a BMD approach
(EFSA, 2010). Developmental neurotoxicity in young children and cardi-
ovascular effects and nephrotoxicity in adults were identified as the rele-
vant endpoints for lead. As a result, EFSA found that neuro-development
effects at current exposure levels are a concern for infants, children and
pregnant women. Consequently, since no threshold of effects for the crit-

Pb
ical endpoints could be identified, EFSA concluded that the JECFA PTWI
is no longer appropriate and that further efforts to derive a PTWI would
not be appropriate. EFSA derived the following 3 BMDLs:
– developmental neurotoxicity BMDL01: 0.50 μg/kg bw/day
– effects on systolic blood pressure BMDL01: 1.50 μg/kg bw/day (90 µg/day)
– effects on prevalence of chronic kidney disease BMDL: 0.63 μg/kg
bw/day (38 µg/day).

Conclusions and recommendations

the SRL for lead is set at 0.01 mg/kg food or food simulant

Since dietary intake of lead in certain populations exceeds levels where

adverse health effects are caused, its release from FCM made from metal
and alloys into food should be reduced as much as possible.
In order to set an SRL for lead, it was decided to use the BMDL10 of
0.63 μg/kg bw/day (38 µg/day) for chronic kidney disease. As lead is con-
sidered an impurity in the metallic material and intake can be higher than
the BMDL10, the allowance for lead release from FCM and articles should
not exceed 10% of the TRV. Therefore, assuming that a person of 60 kg bw
consumes 1 kg of foodstuffs per day that is packaged and/or prepared with
FCM made from metals and alloys, the calculated limit for lead would be
0.004 mg/kg.
However, it was decided to set the SRL at 0.01 mg/kg, which is consistent
with the limit for lead in drinking water, stated in Directive (EU) 2020/2184

169
 Metals and alloys used in food contact materials and articles

to be applicable until January 2036. This equals an allowance of 26% of the

TRV.

References
ANSES. Second French Total Diet Study (TDS 2) - Report 1 - Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Pb

ATSDR. Toxicological profile for lead. US Department of Health and Human Services.
2020 [available at https://www.atsdr.cdc.gov/ToxProfiles/tp13.pdf, accessed 22 Nov 2022].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition. Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
Bergdahl IA, Skerfving S. Lead. In: Nordberg GF, Costa M, editors. Handbook on the tox-
icology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
2022. https://doi.org/10.1016/B978-0-12-822946-0.00036-2.
Bird DW, English TH, Hill WH. Influence of lead migration in tin coatings on
trace metal pick-up from tinplate cans. Br Corros J 1986;21(1):23-6. https://doi.
org/10.1179/000705986798272406.
Bolle F, Brian W, Petit D, et al. Tea brewed in traditional metallic teapots as a significant
source of lead, nickel and other chemical elements. Food Addit Contam Part A Chem Anal
Control Expo Risk Assess 2011;28(9):1287-93. https://doi.org/10.1080/19440049.2011.580010.
Codex Committee on Food Additives and Contaminants (CCFAC). Revised discussion
paper on lead. CX/FAC 95/18-Add.2; 1995.
COT. Statement on the 2006 UK Total Diet Study of Metals and Other Elements. Decem-
ber 2008 [available at https://cot.food.gov.uk/sites/default/files/cot/cotstatementtds200808.
pdf, accessed 21 Nov 2022].
COT. Statement on the potential risks from lead in the infant diet. 2013 [available at https://
cot.food.gov.uk/sites/default/files/cot/cotstatlead.pdf., accessed 25 Nov 2022].
COT. Discussion paper on the effects of lead on maternal health. 2022 [available at https://
cot.food.gov.uk/sites/default/files/2022-02/TOX-2022-05%20Effects%20of%20Lead%20
on%20Maternal%20Health.pdf, accessed 25 Nov 2022].
Dessuy MB, Vale MGR, Welz B, et al. Determination of cadmium and lead in beverages
after leaching from pewter cups using graphite furnace atomic absorption spectrometry.
Talanta 2011;85(1):681-6. https://doi.org/10.1016/j.talanta.2011.04.050.
CEN. Tin and tin alloys. Ref: EN 610:1995.
CEN. Steel for packaging - Flat steel products intended for use in contact with foodstuffs,
products and beverages for human and animal consumption - Tin coated steel (tinplate).
Ref: EN 10333:2005.

170
 Lead (Pb)

EFSA. Scientific Opinion on Lead in Food. EFSA Journal 2010;8(4):1570. https://doi.

org/10.2903/j.efsa.2010.1570.
European Council. Council Directive 69/493/EEC of 15 December 1969 on the approxi-
mation of the laws of the Member States relating to crystal glass. Official Journal of the
European Union 1969;L 326:36-38.
European Council. Council Directive 84/500/EEC of 15 October 1984 on the approxima-
tion of the laws of the Member States relating to ceramic articles intended to come into
contact with foodstuffs. Official Journal of the European Union 1984;27:12-16.
European Parliament. European Parliament and Council Directive 94/62/EC of

Pb
20 December 1994 on packaging and packaging waste. Official Journal of the European
Union 1994;37:10-23.
European Parliament. Directive 2011/65/EU of the European Parliament and of the Council
of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and
electronic equipment (recast). Official Journal of the European Union 2011;54:88-110.
European Parliament. Directive (EU) 2020/2184 of the European Parliament and of the
Council of 16 December 2020 on the quality of water intended for human consumption.
Official Journal of the European Union 2020;63:1-62.
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 837. 1993 [available at https://apps.who.int/iris/handle/10665/36981, accessed
17 Nov 2022].
JECFA. Evaluation of certain food additives and contaminants WHO Technical Report
Series 896. 2000 [available at https://apps.who.int/iris/handle/10665/42378, accessed
17 Nov 2022].
JECFA. Discussion paper on lead (CX/FAC 06/38/28). Thirty-eighth session of the Joint
FAO/WHO Codex Committee on Food Additives and Contaminants, 24-28 April 2006
[available at: https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=h
ttps%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FShared%2BDocume
nts%252FArchive%252FMeetings%252FCCFAC%252Fccfac38%252Ffa38_28e.pdf, accessed
23 Feb 2023].
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 960. 2010 [available at https://apps.who.int/iris/handle/10665/44515, accessed
17 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].

171
 Lithium (Li)

Lithium is a soft, silvery-white metal which tarnishes

and oxidises very quickly on contact with air and
water (Winter, 2007).
Lithium is widely distributed across the globe, but

Li
it is not found in metallic form because of its high
reactivity (Beliles, 1994). It is mainly encountered as an
impurity in the salts of other alkali metals.
Lithium is the lightest solid element. It is mainly used
in the manufacture of certain high-performance
alloys used in aeronautics. Lithium is the metal with
the lowest molecular mass and also the lightest metal,
with a density half that of water. In accordance with
the Dulong-Petit law, it is the solid with the highest
specific heat (Winter, 2007).
Lithium salts such as lithium carbonate, citrate and
orotate are used as mood regulators for the treatment
of bipolar and sleep disorders (Winter, 2007).

Sources and levels of intake

Lithium is found in foodstuffs at concentrations ranging from
0.012-3.4 mg/kg. Grains and vegetables were identified as the main contrib-
utors (Schrauzer, 2002).
Mean daily intake through food from multiple countries was estimated
between 350 and 1500 µg/day (Schrauzer, 2002). ANSES (2011) estimated
mean daily intake at 48.2 μg/person/day in adults and 19.8 μg/person/day in
children. Main contributors are water (35%), coffee and other hot beverages
in adults.

173
 Metals and alloys used in food contact materials and articles

Metallic food contact materials

High-performance lithium-aluminium, -cadmium, -copper and -manga-
nese alloys are used in the manufacture of high-quality mechanical parts,
although there is no evidence of such alloys coming into contact with food.

Other food contact materials

Lithium is sometimes used in low thermal-expansion glasses and ceramics.
Release from plastic FCM is regulated (Regulation (EU) No 10/2011; SML
0.6 mg/kg).
Li

Release
No information available.

Safety aspects
• RIVM (1991) derived a TDI of 0.008 mg/kg bw/day (0.48 mg/day). This
limit was derived from 90-day oral rat studies, mutagenicity data, and
therapeutic uses of Li salts.

Conclusions and recommendations

the SRL for lithium is set at 0.048 mg/kg food or food simulant

Based on the limited information available, the SRL was derived from the
TDI of 0.008 mg/kg bw/day (0.48 mg/day) established by RIVM (1991). As
lithium is considered an impurity in the metallic material, it was concluded
that an allowance of 10% of the TRV was reasonable. Therefore, assuming
that a person of 60 kg bw consumes 1 kg of foodstuffs per day that is pack-
aged and/or prepared with FCM made from metals and alloys, the SRL for
lithium is set at 0.048 mg/kg.

174
 Lithium (Li)

References
ANSES. Second French Total Diet Study (TDS 2) - Report 1 - Inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
Beliles RP. The metals. In: Clayton GD, Clayton FE, editors. Patty’s Industrial Hygiene and
Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
European Commission. Commission Regulation (EU) No 10/2011 of 14 January 2011 on
plastic materials and articles intended to come into contact with food. Official Journal of
the European Union 2011;54:1-89.
RIVM. Summary based on the report RIVM Nr. 105/76 Tox, prepared for EEC SC-Food
Working Group Packaging Materials September 1991.

Li
Schrauzer GN. Lithium: occurrence, dietary intakes, nutritional essentiality. J Am Coll
Nutr 2002;21(1):14-21.
Winter MJ. Lithium: historical information. 2007 [available at https://www.webelements.
com/lithium/history.html, accessed 20 Sep 2021].

175
 Mercury (Hg)

Mercury is among the metals of greatest concern

for human health, especially organic mercury.
Mercury in ambient air originates mainly from
volcanic and industrial activity (Codex Standard
193-1995). About 100 tonnes of mercury are
released into the global atmosphere each year

Hg
by the burning of fossil fuels, melting of sulfide
ores, cement manufacture and the heating of
other materials containing mercury (Florence et
al., 1980). Methyl mercury is biosynthesised from
inorganic mercury as a consequence of microbial
activity (ATSDR, 1999). Methyl mercury is found
in foodstuffs and, in particular, in fish and seafood.
Much has been done in the last decade to eliminate
or reduce mercury contamination of foodstuffs.

Sources and levels of intake

Mercury is found in concentrations ranging from 0.005-0.05 mg/kg in
foodstuffs. The main contributor is methyl mercury in fish, which contains
between 2 and 4 mg/kg. The average level of mercury in fish is 0-0.08 mg/kg
(National Food Agency of Denmark, 1995). The major source of mercury
from fish is methyl mercury (Beliles, 1994; Fowler and Zalups, 2022). In
Commission Regulation (EU) 2023/915, maximum levels for mercury in
relevant foods such as fish, fishery products, crustaceans, salt and in food
supplements have been specified.
The EC (2004) estimated a mean dietary intake of mercury among 13 Euro-
pean states equal to 0.006 mg/day (0.1 µg/kg bw/day). In the UK Total Diet

177
 Metals and alloys used in food contact materials and articles

Study (2014), total mercury was measured (sum of inorganic mercury and
methyl mercury) and mercury was detected at low levels or below the LOD.
The highest concentration was 0.0497 mg/kg measured in the fish group
(FSA, 2014).
ANSES (2011) estimated the mean daily intake of inorganic mercury between
0.006 and 0.18 μg/kg bw/day in adults and between 0.014 and 0.26 μg/kg
bw/day in children (according to LB or UB concentrations). Mean daily
intake of organic mercury via fish and seafood products was estimated at
0.017 μg/kg bw/day in adults and 0.022 μg/kg bw/day in children.
Other sources of mercury may include the chloro-alkali industry, the elec-
trical industry, manufacture of paints, instruments, agrochemicals and
other specialist items.
Hg

Mercury has a propensity to form alloys (amalgams) with almost all other
metals, except iron (Beliles, 1994). Dental amalgam contains tin and silver
(and sometimes gold) dissolved in mercury (Beliles, 1994).
The safety of the use of dental amalgam and its substitutes is subject to spe-
cific risk assessment by the Scientific Committee on Emerging and Newly
Identified Health Risks (SCENIHR). The use of dental amalgam is subject
to Regulation (EU) 2017/852.

Metallic food contact materials

Due to its physico-chemical properties, and in particular its known toxicity,
mercury is not used in FCM.

Release
No information available.

Safety aspects
• JECFA (1978; 1988) established a PTWI of 0.005 mg/kg bw/week for
mercury, but with a maximum of 0.0033 mg/kg bw/week for methyl
mercury. However, it was stated that this PTWI might not adequately

178
 Mercury (Hg)

protect foetuses. In 2010, a new PTWI of 0.004 mg/kg bw/week for inor-
ganic mercury in foods other than fish and shellfish was established
(JECFA, 2010). The previous PTWI for total mercury was withdrawn. The
new PTWI of 0.004 mg/kg bw/week was based on the BMDL (BMDL10 of
0.06 mg/kg bw/day) for a 10% increase in relative kidney weight in male
rats, the application of an uncertainty factor of 100 and extrapolation to
a weekly limit.
• In line with JECFA 2010, the EFSA CONTAM Panel established a TWI
for inorganic mercury of 4 µg/kg bw, expressed as mercury (EFSA, 2012).
• WHO (2022) established a guideline value for inorganic mercury in
drinking water of 0.006 mg/L.
• Mercury, in its metallic form, is unlikely to cause poisoning by ingestion,

Hg
whereas the vapour is toxic. Methyl mercury is the most toxic form of
organic mercury (Codex Standard 193-1995). The oral absorption of ele-
mental mercury is limited and may be approximately 0.1% (Beliles, 1994).
Some inorganic mercury salts and organic mercury compounds may be
more readily absorbed, e.g. methyl mercury which is absorbed completely
(Beliles, 1994). The toxic properties of mercury vapour are due to mercury
accumulation in the brain, causing an unspecific psychoasthenic and veg-
etative neurological syndrome (micromercurialism) (Fowler and Zalups,
2022). At high exposure levels, mercurial tremor is seen, accompanied
by severe behavioural and personality changes, increased excitability,
loss of memory and insomnia (Fowler and Zalups, 2022). Low concen-
trations of methyl mercury cause cell death and inhibition of cell prolif-
eration in cell cultures, whereas mercury chloride primarily disrupts the
plasma membrane (Braeckman et al., 1997). Methyl mercury is listed as
one of the six most dangerous chemicals in the environment. Inorganic
mercury is classified as a carcinogen. However, there is a lack of data on
risks to humans (Beliles, 1994). Mercury and silver interferes with copper
distribution. The general population is exposed to methyl mercury pri-
marily through their diet (organic mercury) and dental amalgam fillings
(inorganic mercury) (ATSDR, 1999).
• An IPCS Working Group (WHO, 2003) recommended a TDI of
0.002 mg/kg bw/day for inorganic Hg based on the NOAEL of 0.23 mg/kg

179
 Metals and alloys used in food contact materials and articles

bw/day for kidney effects from a 26-week study in rats (NTP, 1993) and
applying an uncertainty factor of 100 (for interspecies and intraspecies
variation) after adjusting for dosages 5 days/week. A similar TDI was
obtained by applying an uncertainty factor of 1 000 (an additional uncer-
tainty factor of 10 for adjustment from a LOAEL to a NOAEL) to the
LOAEL for renal effects of 1.9 mg/kg bw/day from a 2-year study in rats
(NTP, 1993).

Conclusions and recommendations

the SRL for mercury is set at 0.003 mg/kg food or food simulant

Mercury is one of the most dangerous metals for human health.

Hg

The SRL was derived from the JECFA (2010) and EFSA (2012) assessments.
Using the TWI of 0.004 mg/kg bw/week as a starting point resulted in
a TDI of 0.0006 mg/kg bw/day (0.03 mg/day). As mercury is considered
an impurity in the metallic material, it was concluded that an allowance
of 10% of the TRV was reasonable. Therefore, assuming that a person of
60 kg bw consumes 1 kg per of foodstuffs day that is packaged and/or pre-
pared with FCM made from metals and alloys, the SRL for mercury is set
at 0.003 mg/kg.

References
ANSES. Second French Total Diet Study (TDS 2) - Report 1 - inorganic contaminants, min-
erals, persistent organic pollutants, mycotoxins and phytoestrogens. June 2011 [available at
https://www.anses.fr/en/system/files/PASER2006sa0361Ra1EN.pdf, accessed 20 Sep 2021].
ATSDR. Toxicological profile for mercury. US Department of Health and Human Services.
1999 [available at https://www.atsdr.cdc.gov/ToxProfiles/tp46.pdf, accessed 22 Nov 2022].
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Toxicology. 4th Edition, Vol II, Part C. New York: John Wiley & Sons, Inc.; 1994.
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of cadmium chloride, mercuric chloride and methylmercuric chloride on cell viability
and proliferation in Aedes albopictus cells. Cell Biol Toxicol 1997;13(6)389-97. https://doi.
org/10.1023/a:1007425925726.
Codex Alimentarius International Food Standards. General Standard for Contaminants
and Toxins in Food and Feed. CXS 193-1995. Adopted 1995; Revised 1997, 2006, 2008,

180
 Mercury (Hg)

2009; Amended 2009, 2010, 2012, 2013, 2014, 2015, 2016, 2017, 2018, 2019 [available at
https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%
252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXS%2B193-
1995%252FCXS_193e.pdf, accessed 24 Nov 2022].
EFSA. Scientific Opinion on the risk for public health related to the presence of mercury
and methyl mercury in food. EFSA Journal 2012;10(12):2985. https://doi.org/10.2903/j.
efsa.2012.2985.
European Parliament. Regulation (EU) 2017/852 of the European Parliament and of the
Council of 17 May 2017 on mercury, and repealing Regulation (EC) No 1102/2008. Official
Journal of the European Union 2017; L 137/1.
European Commission Directorate-General Health and Consumer Protection. Assess-
ment of the dietary exposure to arsenic, cadmium, lead and mercury of the population of
EU Member States. March 2004 [available at https://ec.europa.eu/food/system/files/2016-
10/cs_contaminants_catalogue_scoop_3-2-11_heavy_metals_report_en.pdf, accessed
25 Nov 2022].

Hg
EC. Commission Regulation (EU) 2023/915 of 25 April 2023 on maximum levels for certain
contaminants in food and repealing Regulation (EC) No 1881/2006. Official Journal of the
European Union 2023;L 119/103.
Florence TM, Batley GE, Benes P. Chemical speciation in natural waters. Crit Rev Anal
Chem 1980;9:3:219-296. https://doi.org/10.1080/10408348008542721.
Fowler BA and Zalups RK. Mercury. In: Nordberg GF, Costa M, editors. Handbook on the
toxicology of metals. Volume II, Specific metals. 5th edition. Amsterdam: Academic Press;
2022. https://doi.org/10.1016/B978-0-12-822946-0.00020-9.
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/research/research-projects/
total-diet-study-metals-and-other-elements, accessed 17 Nov 2022].
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 631. 1978 [available at https://apps.who.int/iris/handle/10665/41330, accessed
17 Nov 2022].
JECFA. Evaluation of certain food additives and contaminants. WHO Technical Report
Series 776. 1988 [available at https://apps.who.int/iris/handle/10665/39252, accessed
17 Nov 2022].
JECFA. Evaluation of certain contaminants in food. WHO Technical Report Series 959.
2010 [available at https://apps.who.int/iris/handle/10665/44514, accessed 17 Nov 2022].
National Food Agency of Denmark. Food monitoring 1988-1992. Publication No 232. Min-
istry of Health, Copenhagen; December 1995.
National Institutes of Health, National Toxicology Program (NTP). Toxicology and car-
cinogenesis studies of mercuric chloride in F344/N rats and B6C3F1 mice (gavage studies).
NTP TR 408; NIH Publication No 91-3139; 1993.

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 Metals and alloys used in food contact materials and articles

Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR). Final
opinion on the safety of dental amalgam and alternative dental restoration materials for
patients and users. 2015 [available at https://ec.europa.eu/health/scientific_committees/
emerging/opinions_en, accessed 20 Sept 2021].
WHO IPCS. Elemental Mercury and Inorganic Mercury Compounds: Human Health
Aspects. Concise International Chemical Assessment Document 50. 2003 [available at
https://inchem.org/documents/cicads/cicads/cicad50.htm, accessed 25 Nov 2022].
WHO. Guidelines for Drinking-water Quality. Fourth edition incorporating the first and
second addenda. 2022 [available at https://apps.who.int/iris/handle/10665/352532, accessed
01 July 2023].
Hg

182
 Thallium (Tl)

The Earth’s crust comprises some 0.7% of thallium

(USGS, 2010). Thallium is found in zinc, copper,
iron and lead ores (Peter and Viraraghavan, 2005).
Only very rare minerals (lorandite, crookesite, etc.)
contain thallium (Shaw, 1952). Pyrite ash used to
manufacture cement may contain considerable
quantities of thallium (Peter and Viraraghavan, 2005).

Sources and levels of intake

Tl
According to currently available data, the risk of excessive public exposure
to Tl is low. To date, only a few studies investigating the human health risks
associated with dust deposits from certain industries (e.g. cement works)
have been conducted (Brockhaus et al., 1981). Thallium can be found in
vegetables, potatoes and fish at concentrations around 0.001 mg/kg (FSA,
2014).
Dietary intake was estimated at < 5 µg/day (Sherlock, 1986). In the 2014
UK Total Diet Study the highest total mean and 97.5th percentile exposures
were in the 1.5 to 3 years age group and were 0.021-0.22 µg/kg bw/day and
0.073-0.36 µg/kg bw/day (FSA, 2014).

Metallic food contact materials

This highly toxic metal can be found as an impurity in alloys. The French
Decree of 27 August 1987 lays down a maximal quantity of thallium in alu-
minium of 0.05%. The addition of thallium to certain metals apparently
increases their resistance to deformation and corrosion. However, there is
no evidence of any thallium use in a food-related context, although neither

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 Metals and alloys used in food contact materials and articles

has its absence (as a component or impurity) from metals or alloys been
demonstrated.

Release
No information available.

Safety aspects
• In humans, gastroenteritis, polyneuropathy and alopecia are the classi-
cal symptoms of poisoning. Most assessments are based on a subchronic
90-day-study in rats (MRI, 1988) identifying alopecia as the most critical
endpoint. The authors of this study derived a NOAEL of 0.2 mg/kg bw
from the highest concentration applied.
• The EPA (2009) based their evaluation on the above-mentioned study, but
considered the highest dose of thallium applied (0.2 mg/kg bw/day) as
Tl

LOAEL due to hair follicle atrophy and identified the second highest dose
as NOAEL (0.04 mg/kg bw/day). Due to uncertainties in the study, EPA
chose not to derive an RfD.
• In a 2008 COT (UK) statement, the current UK dietary exposures were
considered unlikely to be of toxicological concern despite the lack of
health-based guidance values for thallium. COT made this assessment
based on the considerations of WHO (1996).
• WHO (1996) considered that exposures resulting in urinary thallium
levels of 5 µg/L are unlikely to cause adverse health effects. This level
corresponds to an oral intake of 10 µg/day of thallium in a soluble form
(0.17 µg/kg bw/day for a 60 kg adult). WHO concluded that due to the
uncertainties relating to thallium toxicity, it could not derive a health-
based exposure limit. Furthermore, in the absence of better dose-response
relationship data, it would seem prudent to ensure that intakes should be
below 10 µg/day.
• Germany’s Environmental Protection Agency – Umweltbundesamt –
derived a HBM-I value of 5 μg/L urine (UBA, 2011) based on an epidemi-
ological study (Brockhaus et al., 1981). The HBM-I-value represents the

184
 Thallium (Tl)

concentration of a substance in human biological material below which

– according to the knowledge and judgement of the HBM Commission
– there is no risk for adverse health effects and, consequently, no need
for action. This was done by correlating the thallium exposure and the
prevalence of certain symptoms known to be associated with chronic
thallium intoxication. This urine concentration corresponded to an oral
exposure of 10 µg/person/day (adult of 60 kg bw).
• The Netherlands’ RIVM evaluated toxicological data available for thal-
lium in 1998. No carcinogenicity studies had been carried out and the
genotoxic potential was examined to a limited extent only. The results
of studies on reproductive toxicity indicate that thallium compounds
adversely affect the male reproductive system. Due to limitations in the
data set, only a provisional TDI (PDTI) could be derived for thallium and
its compounds (0.2 μg/kg bw) (RIVM, 1998).

Conclusions and recommendations

Tl
the SRL for thallium is set at 0.001 mg/kg food or food simulant

The acceptable oral exposure of 10 µg/person/day derived by WHO (1996),

the UBA’s limit (2011) and the PTDI by RIVM are of the same order of mag-
nitude. Therefore, it is recommended to derive the SRL based on these data.
As thallium is considered an impurity in the metallic material, an allow-
ance of 10% of the TRV is applicable. Assuming that a person consumes
1 kg of foodstuffs per day that is packaged and/or prepared with FCM made
from metals and alloys, the SRL for thallium is set at 0.001 mg/kg.

References
Arrêté du 27 août 1987. Matériaux et objets en aluminium ou en alliages d’aluminium au
contact des denrées, produits et boissons alimentaires [Decree of 27 August 1987. Materials
and objects made of aluminium or aluminium alloys in contact with foodstuffs, products
and drinks]. Journal officiel du 27 septembre 1987 [available at https://www.legifrance.gouv.
fr/loda/id/LEGITEXT000006057729/, accessed 25 Nov 2022].
Brockhaus A, Dolgner R, Ewers U, et al. Intake and health effects of thallium among a pop-
ulation living in the vicinity of a cement plant emitting thallium containing dust. Int Arch
Occup Environ Health 1981;48(4):375-89. https://doi.org/10.1007/BF00378686.

185
 Metals and alloys used in food contact materials and articles

COT. Statement on the 2006 UK Total Diet Study of Metals and Other Elements. Decem-
ber 2008 [available at https://cot.food.gov.uk/sites/default/files/cot/cotstatementtds200808.
pdf, accessed 21 Nov 2022].
EPA. Thallium (I) soluble salts; CASRN various. 2009 [available at https://cfpub.epa.gov/
ncea/iris2/chemicalLanding.cfm?substance_nmbr=1012, accessed 25 Nov 2022].
FSA. Measurement of the concentrations of metals and other elements from the 2014 UK
Total Diet Study. 2014 [available at https://www.food.gov.uk/research/research-projects/
total-diet-study-metals-and-other-elements, accessed 17 Nov 2022].
Midwest Research Institute (MRI). Subchronic (90-day) Toxicity of thallium (I) sulfate
(CAS No 7446-18-6) in Sprague-Dawley rats. 1988.
Peter ALJ, Viraraghavan T. Thallium: a review of public health and environmental con-
cerns. Environ Int 2005;31(4):493-501. https://doi.org/10.1016/j.envint.2004.09.003.
RIVM. Maximum permissible risk levels for human intake of soil contaminants:
Fourth series of compounds. March 1998 [available at: https://www.rivm.nl/bibliotheek/
rapporten/711701004.pdf, accessed 22 Nov 2022].
Shaw DM. The geochemistry of thallium. Geochim Cosmochim Acta 1952;2(2):118-54.
https://doi.org/10.1016/0016-7037(52)90003-3.
Sherlock JC, Smart GA. Thallium in foods and the diet. Food Addit Contam 1986;3(4):363-
Tl

70. https://doi.org/10.1080/02652038609373603.
Umweltbundesamt (UBA). Stoffmonographie Thallium − Referenz- und Human-Biomon-
itoring-(HBM)-Werte für Thallium im Urin [Substance Monograph Thallium – Reference-
and Human-Biomonitoring- (HBM) Values for Thallium in Urine]. Bundesgesundheitsbl
2011;54:516-24. https://doi.org/10.1007/s00103-011-1252-y.
US Geological Survey (USGS). Thallium Statistics and Information. 2010 [available at
https://www.usgs.gov/centers/national-minerals-information-center/thallium-statistics-
and-information, accessed 22 Nov 2022].
WHO. IPCS. Thallium. Environmental Health Criteria 182. 1996 [available at http://www.
inchem.org/documents/ehc/ehc/ehc182.htm, accessed 22 Nov 2022].

186
Stainless steels and other alloys

Alloys
An alloy is a metallic material composed of two or more elements. Alloys
are homogeneous at a macroscopic scale and their components cannot be
separated by mechanical means. Alloying elements are incorporated into
the metallic matrix to form a new metallurgical structure that enhances
specific properties of the metal (e.g. tensile strength, corrosion resistance,
electrical or thermal conductivity). The metallurgical structure depends on
the alloy composition, but also on the different thermal and mechanical
processes applied during production of the material.

Main types of alloys

Most metals are mainly used in alloy form. The following alloys are amongst
those most commonly used for food contact applications:
• Steel is an alloy made of iron and carbon (less than 2% carbon). Other ele-
ments (e.g. nickel, chromium and/or molybdenum) may be alloyed with
iron and carbon to provide desired properties.
• Cast iron is an iron alloy containing 2 to 4% carbon and small amounts
of manganese, silicon and phosphorus.
• Stainless steels are iron-chromium alloys which contain a minimum
of 10.5% chromium (usually 17-18%) and less than 1.2% carbon (Euro
Inox, 2009), and which are often also alloyed with elements such as
nickel, molybdenum, etc., to provide desired properties (see Chapter 2
on Stainless steels). Increasing levels of chromium beyond 10.5% further
improves corrosion resistance.

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Metals and alloys used in food contact materials and articles

• Aluminium alloys for FCM may contain alloying elements such as mag-
nesium, silicon, iron, manganese, copper and zinc (European Standard
EN 601; European Standard EN 602).
• Bronze consists of 80-95% copper and 5-20% tin.
• Brass consists of 60-70% copper and 30-40% zinc.
• German silver (also known as nickel silver and Maillechort) is a range of
copper-based alloys with the nickel content ranging from 10-20%. Mail-
lechort has chemical composition of 60-64% copper, 17-19% nickel and
the remainder zinc, which is specified in EN 1652 and has the designation
CW 409J.
• Nickel bronze (also known as dairy bronze and Thai bronze) is an alloy
consisting of 63-67% copper, 3.5-4.5% tin, 3-5% lead, 3-9% zinc, 1.5% iron,
19-21.5% nickel, 1% manganese, and 0.15% silicon.
• Pewter alloy is made up of tin, antimony and copper in the following
percentages: tin 91-95%, antimony 2.5-8%, copper 0.05-2.5%.
• Other alloys are used in small quantities, for example nickel-copper, and
non-stick Al-Cu-Fe-Cr quasi-crystal-coatings.
The composition of an alloy is usually presented as a concentration range for
each individual element. This is because national and international stand-
ards specify permissible concentration ranges. Within the ranges given in
these standards, the properties of the alloy will be the same. Besides the
principal alloying elements that define the alloy type, other ‘minor’ alloy-
ing elements can be added to enhance a specific property of the material
(e.g. the addition of 1-6% Pb in brass to improve the machinability of the
material). Alloys may also contain metallic impurities from raw materials
and production processes. Maximum permissible impurity concentrations
are set in the alloy specification and are generally less than 0.5%, depending
on the alloy type.

Release
Measurable amounts of metallic elements in the alloy may be released
into foodstuffs during food preparation and cooking, leading to human

188
 SAFETY REVIEW AND RECOMMENDATIONS

ingestion. Studies on a variety of metallic FCM have been conducted to

assess whether such releases could impair food quality and/or are a cause
of concern for human health (Flint and Packirisamy, 1995; Flint and
Packirisamy, 1997; Vrochte et al., 1991). In one such study, release tests were
carried out on coffee pots (mocha-type pots) with different compositions of
aluminium alloys. The coffee pots consisted of alloys containing 0.09-0.77%
zinc, 0.19-5.5% copper, 0.02-0.5% lead, as well as other metallic elements.
The release of copper, zinc and lead was determined. The results showed
that increasing amounts of copper in the starting alloy did not correspond
to increased copper release. In addition, repeated use gave irregular, but
decreasing, release of all the tested metals (Gramiccioni et al., 1996).

Safety aspects
• When assessing the risk of the use of one or more substances incorpo-
rated into a special preparation (for instance alloys), the way the constit-
uent substances are bonded in the chemical matrix shall be taken into
account (Regulation (EC) No 1907/2006).
• There are no specific toxicological evaluations for the individual alloys
used for direct food contact and, therefore, any safety assessment is
usually based on the information available for individual elements.
• The constituent elements of an alloy are released from the alloy as indi-
vidual elements.
• There is usually less release of elements from alloys than from unalloyed
metals due to the microstructure and surface properties of the alloys. The
constituents of alloys are bound together in a chemical matrix, essentially
forming solid solutions and new compounds.

Conclusions and recommendations

• Any metallic element released from an alloy should comply with the cor-
responding SRL (see Chapter 1).
• In the absence of a specific safety evaluation of an alloy, the safety of any
released amounts of the individual elements should be evaluated.

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Metals and alloys used in food contact materials and articles

• Cadmium must not be added intentionally.

References
CEN. Aluminium and aluminium alloys – Castings – Chemical composition of castings
for use in contact with foodstuff. Ref: EN 601:2004.
CEN. Aluminium and aluminium alloys – Wrought products - Chemical composition of
semi-finished products used for the fabrication of articles for use in contact with foodstuff.
Ref: EN 602:2004.
CEN. Copper and copper alloys – Plate, sheet, strip and circles for general purposes. Ref:
EN 1652:1997.
European Parliament. Regulation (EC) No 1907/2006 of the European Parliament and
of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisa-
tion and Restriction of Chemicals (REACH), establishing a European Chemicals Agency,
amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93
and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC
and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC. Official
Journal of the European Union 2006;49:1-849.
Flint GN, Packirisamy S. Systemic nickel: the contribution made by stainless-steel cooking
utensils. Contact Dermatitis 1995;32(4):218-24. https://doi.org/10.1111/j.1600-0536.1995.
tb00672.x.
Flint GN, Packirisamy S. Purity of food cooked in stainless steel utensils. Food Addit
Contam 1997;14(2):115-26. https://doi.org/10.1080/02652039709374506.
Gramiccioni L, Beccaloni E, Ciaralli L, et al. Study on the potential migration of metals for
the coffee-makers in alloys based on Al. Aluminium Magazine 1996;9(10):14-19.
Euro Inox. Stainless Steel – When Health Comes First. Environment and Human Health
Series Volume 2. 2009 [available at http://www.worldstainless.org/Files/issf/non-image-
files/PDF/Euro_Inox/WhenHealthComesFirst_EN.pdf, accessed 22 Nov 2022].
Vrochte H, Schätzke M, Dringenberg E, et al. Untersuchungen zur Frage der Nickelfre-
isetzung aus Edelstahlkochtöpfen [The question of nickel release from stainless steel
cooking pots]. Z Ernährungswiss 1991;30(3):181-91. https://doi.org/10.1007/BF01610341.

Stainless steels
Stainless steels are widely used in food contact applications due to their
resistance to corrosion under conditions that would corrode or lead to
rusting of iron or ‘non-stainless’ steels, their durability, and their ability to
be readily cleaned and sterilised without deterioration.

190
 SAFETY REVIEW AND RECOMMENDATIONS

They impart neither colour nor flavour to foodstuffs and beverages.

Corrosion resistance in stainless steels results from a very thin, naturally
formed protective surface layer often called a passive film, which is formed
when the chromium content of the steel exceeds 10.5%. Increasing the chro-
mium content from a minimum of 10.5% to 17 or 20% also increases the sta-
bility of the passive film. This film, only a few nanometres thick (Olsson and
Landolt, 2003), forms almost instantaneously on contact with the oxygen
in air or water. Abrasion or other forms of surface damage do not easily
lead to film breakdown and, if damaged, the film rapidly reforms. Nickel
promotes repassivation and molybdenum is very effective in stabilising the
film in the presence of chlorides. Hence, these two alloying elements are
used in many of the stainless steels used in food contact applications.

Main types of stainless steel

Stainless steels vary in composition, but always contain a high percentage
of chromium (a minimum of 10.5%). The majority of stainless steels used in
food contact applications contain 16-18% of chromium (except martensitic
stainless steels for cutlery and knife blades), as this has been found to be the
optimum chromium concentration for corrosion resistance in a wide range
of food and beverages.
Stainless steels may be sub-divided into families according to their met-
allurgical structure. The European Standard EN 10088 series specifies the
chemical composition of stainless steels, some of which are commonly
used for food contact applications:
• Martensitic stainless steels: 11.5-19% chromium with low (0-2%) or
medium (4-7%) nickel. They may contain molybdenum (up to 2.8%) and
vanadium (up to 0.2%). Sub-families with varying amounts of carbon,
with or without molybdenum, are used for particular applications. Some
typical compositions and applications are:
– 13% chromium, 0.2% carbon, no nickel or molybdenum, used for
medium-price cutlery.
– 13% chromium, 0.4% carbon, plus molybdenum, no nickel, used for
high-quality cutlery.

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Metals and alloys used in food contact materials and articles

– 14-15% chromium, > 0.4% carbon, 0.5-0.8% molybdenum, 0.1-0.2%

vanadium, no nickel, used for professional chef’s knives.
• Ferritic stainless steels: minimum 10.5-30% chromium and maximum 1%
nickel. Some grades may contain up to 4% molybdenum, and aluminium
may be used as an alloying element. 16-21% chromium is used in cutlery,
holloware, table surfaces, panels and worktops.
• Austenitic stainless steels: for food contact applications, typically contain
a minimum of 16% chromium and 6% nickel. Austenitic grades (mainly
the so-called 300 series stainless steels) with varying amounts of chro-
mium and nickel, sometimes with other elements (e.g. molybdenum,
copper), are used in a very wide range of food contact applications: both
domestic and industrial cutlery, holloware and kitchen utensils typically
having 18% chromium and 8-10% nickel; higher alloy grades used for food
processing, storage and transport equipment, pipe-work, etc., having 17%
chromium, 11% nickel and 2% molybdenum. Grades containing molyb-
denum (approximately 2-3%) are particularly resistant to the corrosion
caused by salt-containing foods (Euro Inox 2006).
The so-called 200 series stainless steels, where manganese (up to 8%) is sub-
stituted for nickel, are also used for food contact applications (cookware,
baking tins, serving implements, etc.). These grades also contain nitrogen
and copper to further stabilise the austenitic structure of the steel and which,
respectively, provide additional strength and improved cold forming prop-
erties. However, although the 200 series are austenitic stainless steels, their
corrosion resistance is generally not equal to that of the 300 series stainless
steels. According to EN ISO 8442-2 austenitic stainless steels for cutlery are
divided into two groups:
• CrNi –17% Cr (min), 8% Ni (min) (300 series)
• CrNiMn –17% Cr (min), 4% Ni (min), 7.5% Mn (max) (200 series)
• Super-austenitic grades (typically containing 20-25% chromium, 20-25%
nickel, 4.5-6.5% molybdenum and sometimes with copper additions) are
used in contact with food containing very high levels of salt (e.g. soy
sauce) and also for steam-heating systems, boilers, briners, etc.

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 SAFETY REVIEW AND RECOMMENDATIONS

• Austenitic-ferritic steels, also known as duplex steels, contain 21-28%

chromium, 0-4.5% molybdenum, 1.35-8% nickel, 0.05-0.3% nitrogen and
up to 1% tungsten. These stainless steels may be used in contact with cor-
rosive foodstuffs as they have a very high resistance to corrosion caused
by, for example, saline solutions at high temperatures.

Composition limits
There are no universal composition limits for stainless steels used in food
contact applications, although there are legislative requirements in France,
Italy and Greece. In France, stainless steels for food contact products
must contain at least 13% chromium and can contain nickel and manga-
nese. Maximum limits are imposed for certain other alloying elements (4%
for Mo, Ti, Al and Cu; 1% for Ta, Nb and Zr). In Italy, there is a positive
list of stainless steel grades for use as FCM. These grades must pass metal
release tests for corrosion in distilled water, olive oil, an aqueous solution of
ethanol and 3% acetic acid in water, under specified conditions. New grades
can be added to the positive list following appropriate testing. In Greece,
stainless steels for food contact products must contain at least 12% (w/w)
of chromium. Maximum limits are imposed for certain other alloying ele-
ments (4% for Mo, Ti, Al and Cu; 1% for Ta, Nb and Zr; 0.5% for Pb; 0.05%
for Cd and 0.05% for As). In the UK, there are numerous specifications for a
wide range of food contact applications for stainless steels. Other countries
also have similar regulations. References to some of the Italian, French, UK
and German legislation/standards (e.g. DIN 18 865 and DIN 18 866) are
included in the Bibliography.
In addition, there are European and International standards for certain
types of application of stainless steels. The composition limits for stainless
steels for table cutlery (knives, forks, spoons, carving sets, ladles, children’s
cutlery and other serving utensils) are specified in EN ISO 8442-2; specified
compositions are linked to the application of the table cutlery.
Compositional information on some other grades of stainless steels used in
food contact applications can be found in the Outokumpu Stainless Corro-
sion Handbook (2017).

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Metals and alloys used in food contact materials and articles

Stainless steels used in contact with food

The following food contact applications often use stainless steels:
i. Containers for storage and transportation, e.g. milk trucks, wine
tanks.
ii. Processing equipment used in industrial plants, e.g. equipment for
processing fruit and vegetables, dry foods such as cereals, flour, sugar,
and fish, as well as brew kettles and beer kegs, utensils such as blend-
ers and bread-dough mixers.
iii. Processing equipment, as well as many fittings in catering facilities
such as restaurants, hospitals and in industrial kitchens.
iv. Slaughterhouse equipment.
v. Household equipment, e.g. electric kettles, cookware, kitchen fittings
(sinks, counters) as well as bowls, knives, spoons and forks.
A wide range of stainless steels is highly resistant to corrosion in acetic
acid (concentration range 1-20%) at temperatures up to boiling point
(Outokumpu, 2017). Similar corrosion resistance is seen for beer, citric acid
(up to 5%), coffee, fruit juices, wines, lactic acid, milk and various deter-
gents. It is well known that molybdenum improves the corrosion resist-
ance of stainless steels in contact with foods or fluids that contain chloride
ions. In Italy, stainless steels must meet certain release criteria in a variety
of media before they can be approved for food contact applications. The
list of approved stainless steels includes the standard austenitic grades 304
(18% Cr, 10% Ni) and 316 (17% Cr, 12% Ni+Mo). In addition, some European
standards (e.g. EN ISO 8442-2) specify the finished quality of the products
and their ability to meet test criteria, which minimises the likelihood of
pitting or crevice corrosion occurring during the normal lifetime of the
product.
In addition to corrosion resistance, grade selection for food applica-
tions must also include consideration of durability, formability (e.g. deep
drawing for pots and pans) and mechanical/physical properties (e.g. fer-
romagnetism for induction heating applications). Users of this Technical
Guide are recommended to seek expert advice on the selection of suitable
stainless steel grades for their specific food contact applications.

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 SAFETY REVIEW AND RECOMMENDATIONS

Release
Metal ion release from stainless steels is generally assumed to be a
time-dependent measure of metal transition. Tests have shown that metal
release from stainless steels decreases with time (Mazinanian et al., 2016).
Further information on these processes can be obtained from the literature
cited below.
Preparation of foodstuffs such as rhubarb, sauerkraut and red wine sauce in
brand new stainless steel cooking pots may cause chemical changes of the
stainless steel surface. These changes can be regarded as the development
of a protective layer that reduces further nickel release (Bünig-Pfaue and
Strompen, 1999). The amount of nickel derived from food contact utensils
in standard portions of various corrosive foodstuffs is 0-0.008 mg (Flint
and Packirisamy, 1995).
The highest rates of chromium and nickel release from saucepans were
observed in new saucepans at first use (Flint and Packirisamy, 1997). Nickel
and chromium release was tested with rhubarb, apricots, lemon marma-
lade, tomato chutney and boiled potatoes. The average release of nickel was
0.21 mg/kg for apricots and 0.14 mg/kg for rhubarb after the first cooking
operation. After the fifth cooking operation, the highest nickel release
for apricots and rhubarb was reduced to approximately 0.06 mg/kg and
0.03 mg/kg, respectively. Correspondingly, the highest release of chromium
after the fifth cooking operation was 0.04 mg/kg for both.
Using boiling 5% acetic acid as a simulant for 5 minutes in stainless steel
pans, nickel release ranged between 0.08 and 0.21 mg/kg (Kuligowski and
Halperin, 1992). A study of the levels of nickel and chromium found in 11
foodstuffs commonly cooked in glass and stainless steel saucepans showed
values within or close to the range of nickel and chromium contents of
these foods reported in the literature (Accominotti, 1998).
A review on the metal release from stainless steel in biological environ-
ments, including food, is available (Hedberg et al., 2016).

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Metals and alloys used in food contact materials and articles

Safety aspects
• No particular health concerns have been raised, in terms of excessive
intakes of nickel or chromium, by several studies of metal release in
various media and of the uptake of metals by foods cooked in stainless
steel pans.
• Special grades of stainless steels are available for use in applications
where particular corrosion resistance characteristics are required (e.g.
those involving contact with relatively high levels of chloride ions).
Compliance with SRLs, as presented in this Technical Guide, will help to
reduce health risks that may arise from the use of certain stainless steels
that are not well known or that have not been individually tested.

References
Accominotti M, Bost M, Haudrechy P, et al. Contribution to chromium and nickel enrich-
ment during cooking of foods in stainless steel utensils. Contact Dermatitis 1998;38(6):305-
10. https://doi.org/10.1111/j.1600-0536.1998.tb05763.x
Bünig-Pfaue H, Strompen C. Hinweise zur Gebrauchssicherheit von Edelstahlkochtöpfen –
Untersuchungen zum möglichen Nickel-Übergang aus Edelstahl in Kochgut [Information
on the safety in use of stainless steel cooking pots – Investigations on the possible nickel
transition from stainless steel into cooking food]. Forschungsbericht. Düsseldorf: Verlag
und Vertriebsgesellschaft mbH; 1999: 246.
Deutsches Institut für Normung (DIN). Großküchengeräte - Heißumluftgeräte und
Heißluftdämpfer - Anforderungen und Prüfung [Equipment for commercial kitch-
ens - Convection ovens and convection steamers - Requirements and testing]. Ref: DIN
18866:2022.
Deutsches Institut für Normung (DIN) 10528:2017. Lebensmittelhygiene - Anleitung für
die Auswahl von Werkstoffen für den Kontakt mit Lebensmitteln - Allgemeine Grundsätze.
[Food hygiene - Guideline for the selection of materials used in contact with foodstuffs -
General principles]. Ref: DIN 10528:2017.
CEN. Materials and articles in contact with foodstuffs - Catering containers - Part 1:
Dimensions of containers. Ref: EN 631-1:1993.
Euro Inox. Stainless Steel in the Food and Beverage Industry. Materials and Applica-
tions Series, Volume 7, 1st Edition. 2006 [available at https://www.worldstainless.org/
Files/issf/non-image-files/PDF/Euro_Inox/StSt_in_FoodandBeverage_EN.pdf, accessed
21 Nov 2022].

196
 SAFETY REVIEW AND RECOMMENDATIONS

Flint GN, Packirisamy S. Systemic nickel: the contribution made by stainless-steel cooking
utensils. Contact Dermatitis 1995;32(4):218-24. https://doi.org/10.1111/j.1600-0536.1995.
tb00672.x.
Flint GN, Packirisamy S. Purity of food cooked in stainless steel utensils. Food Addit
Contam 1997;14(2):115-26. https://doi.org/10.1080/02652039709374506.
Hedberg YS, Odnevall Wallinder I. Metal release from stainless steel in biological environ-
ments: A review. Biointerphases 2016;1(1);018901. https://doi.org/10.1116/1.4934628.
ISO. Materials and articles in contact with foodstuffs – cutlery and table holloware – Part 1:
Requirements for cutlery for the preparation of food. Ref: ISO 8442-1:1997.
ISO. Materials and articles in contact with foodstuffs – Cutlery and table holloware –
Part 2: Requirements for stainless steel and silver-plated cutlery. Ref: ISO 8442-2:1997.
Kuligowski J, Halperin KM. Stainless steel cookware as a significant source of nickel, chro-
mium, and iron. Arch Environ Contam Toxicol 1992;23(2):211-15. https://doi.org/10.1007/
BF00212277.
Mazinanian N, Herting G, Odnevall Wallinder I, et al. Metal release and corrosion resist-
ance of different stainless steel grades in simulated food contact. Corrosion 2016;72(6):775-
90. https://doi.org/10.5006/2057.
Olsson COA, Landolt D. Passive films on stainless steels – chemistry, structure and growth.
Electrochim Acta 2003;48(9):1093-104. https://doi.org/10.1016/S0013-4686(02)00841-1.
Outokumpu. Handbook of Stainless Steel. 2017 [available at https://www.outokumpu.com/
en/expertise/2021/corrosion-guides, accessed 22 Nov 2022].
CEN. Stainless steels - Part 1: List of stainless steels. Ref: EN 10088-1:2014.
CEN. Stainless steels - Part 2: Technical delivery conditions for sheet/plate and strip of
corrosion resisting steels for general purposes. Ref: EN 10088-2:2014.
CEN. Stainless steels - Part 3: Technical delivery conditions for semi-finished products,
bars, rods, wire, sections and bright products of corrosion resisting steels for general pur-
poses. Ref: EN 10088-3:2014.

Bibliography
Arrêté du 13 janvier 1976. Matériaux et objets en acier inoxydable au contact des denrées ali-
mentaires [Decree of 13 January 1976. Stainless steel materials and articles in contact with
foodstuffs]. Journal officiel de la République française 31 janvier 1976 [available at https://
www.legifrance.gouv.fr/jorf/id/JORFTEXT000000637961, accessed 22 Nov 2022].
British Standards Institution (BSI). Specification for domestic pressure cookers. Ref:
BS 1746:1987.
British Standards Institution (BSI). Stainless steel tubes and fittings for the food industry
and other hygienic applications. Specification for tubes. Ref: BS 4825-1:1991+A2:2009.

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British Standards Institution (BSI). Stainless steel tubes and fittings for the food industry and
other hygienic applications. Specification for bends and tees. Ref: BS 4825-2:1991+A2:2009.
British Standards Institution (BSI). Stainless steel tubes and fittings for the food indus-
try and other hygienic applications. Specification for clamp type couplings. Ref:
BS 4825-3:1991+A2:2009.
British Standards Institution (BSI). Stainless steel tubes and fittings for the food indus-
try and other hygienic applications. Specification for threaded (IDF type) coupling. Ref:
BS 4825-4:1991+A1:2009.
British Standards Institution (BSI). Stainless steel tubes and fittings for the food industry
and other hygienic applications. Specification for recessed ring joint type couplings. Ref:
BS 4825-5:1991+A1:2009.
British Standards Institution (BSI). Specification for table cutlery with non-metallic
handles. Ref: BS 5577:1999.
Decreto Ministeriale del 21 Marzo 1973. Disciplina igienica degli imballaggi, recipienti,
utensili, destinati a venire in contatto con le sostanze alimentari o con sostanze d’uso
personale [Ministerial Decree of 21 March 1973. Hygiene control of packaging, containers,
tools, intended to come into contact with foodstuffs or with substances for personal use].
Gazzette Ufficiali della Repubblica Italiana no 104, 20 April 1973.
Deutsches Institut für Normung (DIN) 10528:2017. Lebensmittelhygiene - Anleitung für
die Auswahl von Werkstoffen für den Kontakt mit Lebensmitteln - Allgemeine Grundsätze
[Food hygiene - Guideline for the selection of materials used in contact with foodstuffs -
General principles]. Ref: DIN 10528:2017.
Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 2:
Warmausgaben, Anforderungen und Prüfung. [Equipment for commercial kitchens -
Food distribution equipment - Part 2: Heated service counters; requirements and testing].
Ref: DIN 18865-2:2021.
Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 4:
Aufbauten, beheizt oder unbeheizt - Anforderungen und Prüfung [Equipment for com-
mercial kitchens - Food distribution equipment - Part 4: Top shelves heated or not heated -
Requirements and testing]. Ref: DIN 18865-4:2018.
Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 5: Tab-
lettrutschen [Equipment for commercial kitchens - Food distribution equipment - Part: 5:
Tray slides]. Ref: DIN 18655-5:2021.
Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 6:
Einbaustapelgeräte (beheizt oder unbeheizt) [Equipment for commercial kitchens - Food
distribution equipment - Part 6: Dispensers (heated or unheated)]. Ref: DIN 18865-6:2021.
Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 7:
Kaltausgabegeräte (Kühlgeräte) [Equipment for commercial kitchens - Food distribution
equipment - Part 7: Cold storage (Refrigerators)]. Ref: DIN 18865-7:2021.

198
 SAFETY REVIEW AND RECOMMENDATIONS

Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 8: Auf-

bauten, gekühlt [Equipment for commercial kitchens - Food distribution equipment - Part
8: Top shelves refrigerated]. Ref: DIN 18865-8:2021.
Deutsches Institut für Normung (DIN). Großküchengeräte - Ausgabeanlagen - Teil 9:
Schrankinnenräume in Standard- und in Hygieneausführung [Equipment for commercial
kitchens - Food distribution equipment - Part 9: Equipment-insides in basic and hygiene
version]. Ref: DIN 18865-9:2021.
Norme française. Acier hors emballage - Acier inoxydable destiné à entrer au contact des
denrées, produits et boissons pour l’alimentation de l’homme et des animaux [Stainless
steel intended for use in contact with foodstuffs, products and beverages for human and
animal consumption]. Ref: NF A36-711.

199
Chapter 3 – Release testing of food
contact materials and articles made from
metals and alloys

Resolution CM/Res(2020)9 on the safety and quality of materials and

articles for contact with food establishes that compliance of the FCM and
articles with the relevant provisions and restrictions shall be verified by
appropriate scientific methods (including modelling or worst-case calcula-
tions) in accordance with Regulation (EU) No 2017/625 or relevant national
legislation.
Furthermore, tests on release from the material or article into foodstuffs
are carried out under the conditions of manufacture, storage, distribution
and normal/foreseeable use considered to be a ‘reasonable worst-case’ with
respect to contact time, temperature and composition of the foodstuff.
The results of SR testing obtained in food shall prevail over the results
obtained in food simulants.

Criteria for the choice of test procedure

To assess compliance (see Calculation of specific release), the material or
article must be tested for the release of the relevant metals and impurities,
either into foodstuffs or into food simulants, according to the following
criteria.

Testing release from materials and articles into

foodstuffs
Release from metallic materials and articles into foodstuffs is influenced
by the properties of the material, the chemical and physical properties of

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Metals and alloys used in food contact materials and articles

the foodstuff, and ambient conditions such as thermal processing of filled

containers, storage time and temperature and residual oxygen after sealing.
To verify the compliance of materials or articles with the relevant SRLs,
actual foodstuffs are tested or used in testing under actual conditions of
application in the following cases:
• when the material or article placed on the market is already in
contact with food (canned food, beer kegs, etc.) and as far as possible
at the end of shelf life.
• when the material or article is not yet in contact with food, but the
intended use for specified foodstuff(s) or group(s) of foodstuffs is
clearly indicated by the manufacturer or is undoubtedly recognised
(food processing utensils such as garlic presses, tea infusers, etc.).
• when harsh physical conditions or abrasion are expected to be
encountered under normal use that cannot be reproduced when
using liquid simulants (pepper mills, coffee grinders or other mills
for nuts, cereals, etc.).
When the natural metal content of the foodstuffs is capable of significantly
influencing the analytical result, an alternative representative food can be
used. The natural metal content of the foodstuff should be considered and
reported with the analytical result (see Natural metal content of the foods-
tuff, Release testing into foodstuffs).

Testing release from materials and articles into

food simulants
Following the guiding principles established by Resolution CM/Res(2020)9,
food simulants are used instead of foodstuffs when release testing in food
is not feasible or not practical, as described below:
• the material or article may come into contact with foodstuffs whose
diversity cannot be included in a particular category of food (e.g.
kitchen utensils or other articles at end-use level).
• the intended use for specified foodstuff(s) or group(s) of foodstuffs is
not clearly indicated or known.

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• the analysis is not technically possible or the specified foodstuff(s) or

group(s) of foodstuffs are not available.
The food simulants and conditions of contact are selected in such a way that
release is at least as high as into food.

Articles for repeated use

For materials or articles not yet in contact with food (i.e. non-packaging
applications) but intended to come into repeated contact with foodstuffs,
the release test(s) shall be carried out three times in succession. Between
tests, samples are treated as described under Pre-treatment of materials
and articles. Where these instructions apply only to the first use or where
the instructions indicate that no washing is required before or between
uses, this must be taken into account.
Compliance is established based on:
• the findings from the third test. This takes account of the passivation
process that some alloys or metals undergo.
• the sum of the results of the first and second tests that should not
exceed an exposure equivalent to daily use for one week (i.e. seven
times the SRL) according to the formula:
RESULT1st test + RESULT2nd test ≤ 7 × SRL
This takes into account the overall acceptability of a food contact article.
Care should be taken so that repeated-use articles made from plated metals
or alloys are produced in such a way that the integrity of the plating is
guaranteed throughout their lifetime. Such items should be labelled with a
warning that in case of any defect, they may no longer be safe for use.
Articles for repeated use, like hot beverage appliances (e.g. coffee machines),
should be tested after any preparatory or cleaning steps (e.g. decalcifica-
tion) stated within the corresponding instruction manual.

Remark
Where relevant physical changes (like corrosion) occur in the test specimen
only under the specified test conditions, but not under the worst foreseeable

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Metals and alloys used in food contact materials and articles

conditions of use of the material or article, the test must be adapted with
alternative conditions that do not lead to the physical changes but still reflect
the worst foreseeable conditions of use.

Sampling of materials and articles

Sampling for analysis means taking an article, a material or an already
packed food item in order to verify its compliance with the established
requirements, such as relevant SRLs.
Sampling should be performed at all stages of the supply chain for FCM.
A sampling strategy should be defined which allows an appropriate and
representative sample of the production batch to be obtained. The type,
amount, size and characteristic properties of the sample should, as a
minimum, be specified.
The number of test specimens sampled and the sample size must be suffi-
cient to perform repeat analyses and to confirm results in case of dispute.
For each sampling effort, an appropriate sampling protocol form should be
prepared, which must be completed during the sampling exercise. When
sampling for enforcement purposes, replicate samples should be taken for
primary analysis, disputes (in which case, analyses should be repeated) and
confirmatory analyses (if results are challenged, analyses should be per-
formed by different laboratories), unless such a procedure conflicts with
the rules of member states as regards the rights of the food manufacturer.

Packaging materials (e.g. cans)

A sampling strategy should be developed in order to check batch compli-
ance for packaging materials at the manufacturing or distribution stage,
which should be reflected in the supporting documentation of any dec-
laration of compliance. An example of a sampling plan for this purpose
is given in Table 1 and may be applied. Different sampling plans can be
used; however, they should not be seen as substitute for an effective process
control (Commission Regulation (EC) No 2023/2006).

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Table 1. Number of packages or units to be sampled, depending on the batch size

Number of packages or units Number of packages or units

in the batch to be sampled
≤ 59 at least 3
60-200 at least 5%
> 200 10

Materials and articles other than packaging materials (e.g. kitchen

utensils)
At least three replicated samples should be sampled.

Competent authorities/inspectorates
In official controls (e.g. as part of a market surveillance campaign), the
number of samples and the sample size may differ from the sampling plan
referred to above.

Pre-treatment of materials and articles

Any instructions provided by the manufacturer with regard to pre-treatment
of the test specimens, such as cleaning, must be followed before release
testing is performed.
When washing is required and no detailed instructions are provided, test
specimens should be washed with dishwashing soap/detergent in water
(pH 6-8.5, at a temperature of approximately 40°C), then rinsed with tap
water and finally with distilled water or water of similar quality. They
should be left to drain and dry. Any staining should be avoided. The surface
to be tested must not be handled after cleaning.
During the sample preparation, modification of the physical proper-
ties of the surface of the FCM or article should be avoided, especially for
metal-plated products.

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Metals and alloys used in food contact materials and articles

Release testing into foodstuffs

Pre-treatment and handling of materials and articles, where appropriate,
are described under Pre-treatment of materials and articles.
If appropriate, test conditions may be selected using the times and temper-
atures set out under Testing release from materials and articles into food
simulants. However, these conditions for testing into food simulants could
be inappropriate for food (e.g. causing deterioration/alteration of the food).
In such cases, the conditions of worst foreseeable real use should be selected.

Selection of foodstuffs
The material or article to be tested shall be brought into contact with the
intended foodstuff, if available. Contact surface to volume ratio is impor-
tant – whenever possible, tests should be performed with the real surface
to volume ratio.
If no particular foodstuff has been indicated, a representative foodstuff
should be selected, especially one with an equivalent pH value and organic
acid, salt, fat and alcohol content. The principle of reasonable worst-case cir-
cumstances of use shall be applied. For example, testing should be carried
out in the presence of known corrosion accelerators, such as sulfur dioxide
or nitrate, if these substances are reasonably foreseeable to be present in the
foodstuff and at levels close to their typical upper limits.
Where applicable, the representative foodstuff will be specified in the sup-
porting documentation of any declaration of compliance and, if necessary,
the initial concentration of the metal(s) before release testing. This is to
ensure that the tests can be reproduced, if necessary.
NOTE: Souci et al. (2016) have created Food Composition and
Nutrition Tables that the reader may find helpful. For example, this
reference identifies foodstuffs with the highest concentrations of
typical organic acids.

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Natural metal content of the foodstuff

There should be prior knowledge of the natural concentration of the metal(s)
in the foodstuff to be tested. Therefore, the metal concentration in the food-
stuff needs to be measured before and after contact with the metallic mate-
rial or article. If available, information about the expected natural metal
concentration and its variability (at least minimum – maximum values) in
the foodstuff should be mentioned in the supporting documentation of any
declaration of compliance.

Testing of packaging materials

Processing and packaging conditions*

When checking compliance, test conditions should be as close as pos-
sible to actual processing and packaging conditions to avoid an over- or
under-estimation of metal release. The presence of oxygen during the test,
for example, may increase the release of iron and tin from tinplate cans
or of aluminium from aluminium containers. Metal containers must be
hermetically sealed (i.e. closed in such a way that air is prevented from
entering or leaving the enclosure).
If a vacuum is created in the container after sealing under actual packag-
ing conditions, an equivalent vacuum should also be created in the test
packaging.
If hot foodstuffs are packed into containers under industrial packaging
conditions, then this should also be carried out for testing purposes.

Storage conditions*
Most hermetically closed metal containers for foodstuffs are used for prod-
ucts with long shelf-lives that may, in some cases, extend up to 5 years.
It is likely that the release of metals due to interactions between foodstuffs
and the food contact surface of metal containers will continue throughout
the shelf life of the product. The increase in the concentration of metals in

* These conditions may be suitable for manufacturers, while competent authorities

may not be able to replicate industrial conditions. Thus, comparison of their respec-
tive results may not be possible.

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Metals and alloys used in food contact materials and articles

packed foodstuffs may not be linear in all cases. Therefore, it is not possible
to accurately predict the concentration of the metal at the end of the shelf
life based on measurements taken only after storage for a short time.
Consequently, it is advisable to store the test specimens under actual storage
conditions for its entire shelf life.
If rapid test results are needed, metal release can be accelerated by using
more challenging storage conditions, for example, higher temperatures,
regular shaking of the container, or alternating between hot and cold
storage. The extrapolation of these data must be justified by comparison
with data obtained under normal conditions. For example, after verifica-
tion of their applicability (scientifically validated), the contact time and
temperature tables reported in Regulation (EU) No 10/2011, Annex V, could
be used.
The information on any accelerated testing must be mentioned in the sup-
porting documentation of any declarations of compliance.

Determination of metals in the foodstuff

The metal concentration in the foodstuff can usually be determined using
the same analytical methods as for the determination of metal concentra-
tions in food simulants. Individual digestion conditions and particular
measures to avoid matrix interference may be required. In the case of any
special sample treatment, a thorough description of instrumental condi-
tions must be included in the test report.

Test results
The release of a particular metal from a metallic FCM or article (SR) into
foodstuffs can be determined by subtracting the concentration of the
element in the foodstuff before contact with the metal/alloy (C0) from
the concentration of the element in the foodstuff after contact with the
metal/alloy (C1):
SR = C1 – C0 expressed in [mg Me/kg food] or in [mg Me/dm2].

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Release testing into food simulants

Food simulants
As it is not always possible to test release from FCM and articles into actual
foodstuffs, food simulants have been introduced that share certain charac-
teristics with one or more food types. In practice, various mixtures of food
types are possible, for instance fatty and aqueous foods.
Taking into account sound scientific knowledge, tests conducted in the
context of this Technical Guide and the principle of reasonable worst-case
conditions of use, testing on the following food simulants is recommended:

Table 2. Food types and food simulants

Type of food Simulant

Aqueous or alcoholic or fatty food Artificial tap water (ATW) EN 16889*
Acidic foods (pH ≤ 4.5) Citric acid 0.5% (m/v)†

* EN 16889:2016 Approximate ion concentrations: calcium 16.4 mg/L, magnesium 3.3 mg/L,
sodium 16 mg/L, hydrogen carbonate 44 mg/L, chloride 28.4 mg/L, sulfate 13 mg/L and pH
adjusted to 7.5 using 0.1M NaOH or 0.1M HNO3. ATW (pH 7.5) should be prepared fresh every
day. When used for a release test at 100°C, it should be heated slowly to a gentle boil, to
avoid changes in the pH. After the release test, a few drops of HNO3 acid should be added
to avoid metal ion precipitation.
†
Prepared by dissolving 5 g of citric acid monohydrate (CAS No 5949-29-1) in distilled water
and diluting to final volume of 1 L.

If an article is intended for contact with only a specific dry food it should
be tested with that food.
Any other food simulant, considered to be more suitable for testing, can be
used provided that its use is either based on scientific data or verified by
appropriate experimentation.
Distilled water at the same temperature as the test material should be added
regularly during testing to replace the quantity of food simulant lost by
evaporation.
To cover (close) a receptacle when it has no lid, an appropriate covering
(e.g. fluoroplastic film) may be placed on top. Containers that have a cover

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Metals and alloys used in food contact materials and articles

should be closed as under actual conditions (e.g. for metal cans the experi-
mental set-up should imitate the absence of oxygen).

Articles that can be filled

Kitchenware articles and other articles that can be filled should be filled
with the food simulant to approximately ⅔ total capacity and then suitably
covered to reduce evaporation. Metal cans should be filled to their nominal
volume. The same volume (or mass) of food or simulant must be used for
replicate analysis and this volume (or mass) must be reported.
A distinction between use at ambient temperature, cold fill (e.g. for salads)
and uses that include hot fills or boiling liquids should be made.
Kitchenware should be tested under actual conditions of use (temperature,
time, volume or mass) or by applying the test conditions as specified in the
JRC Guidelines on testing conditions for kitchenware articles in contact
with foodstuffs (Beldi et al., 2021). The temperature refers to the tempera-
ture of the simulant at the surface in contact with the article.
Articles other than kitchenware should be also tested under actual condi-
tions of use; however, if not practical (e.g. 2 years at room temperature for
cans or even longer), other testing conditions can be used after describing
the rationale behind the selection of the testing conditions.
Due to practical limitations, these conditions do not apply to large-volume
equipment such as pipes and tanks.

Articles that cannot be filled

A. Articles for which it is impractical to estimate the ratio of surface area

to the amount of foodstuff in contact with it
Test conditions for articles including cutlery and cooking utensils such as
colanders, potato mashers and cheese graters:
The article should be tested, intact, by immersion to a reasonable depth
reflecting normal use of the article (see Annex I for a detailed procedure).

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 RELEASE TESTING OF FCMs AND ARTICLES MADE FROM METALS AND ALLOYS

For the purpose of the test, contact times and temperatures should repro-
duce the intended and worst foreseeable conditions of use of the material or
article (see Beldi et al., 2021).

B. Materials and articles at the end-use level that cannot be filled other
than A
This applies to materials and articles such as aluminium foil, cutting boards,
kitchen sinks with draining boards and kitchen countertops.
Either the entire article or a test specimen of it can be tested by immersion
of the relevant surfaces intended for contact with food. In the latter case,
the total area of the test specimen should be at least 1 dm2, determined
with a measurement precision of 1 mm for each side. Only the food contact
surface is taken into account when determining the SR value. For symmet-
rical samples only, including both surfaces in the calculation is sometimes
valid. This is when it can be shown that the SR value obtained in the total
immersion test including both surfaces in the calculation is, allowing for
analytical tolerance, the same as that obtained by single surface testing.
The areas of cut edges are taken into account only if their thickness exceeds
2 mm.
The ratio of the food contact area to simulant volume during the test is
maintained equal to the one during actual use. If the actual area to volume
ratio is not known, it is set to 6 dm2/kg simulant and this is reported. Testing
conditions are selected as described above for articles that can be filled.
As an alternative to testing by immersion, an appropriate set-up (e.g. apply-
ing a glass jar to a metal lid) or a test cell for samples of flat (non-fillable)
articles can be used. The sample is mounted to the test cell with the food
contact surface facing towards the foodstuff or food simulant.
Test cells can be used if the applicable test conditions as described in the
JRC guideline are met (Beldi et al., 2021).
Test cells should be as close as possible to being inert with respect to the
applied foodstuffs or food simulants. A blank test must be performed in
order to measure the potential release of metals from the test cell itself. In
the blank configuration, an inert sheet that does not release any metals

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should be used in place of the sample. The results of the blank test have to
be subtracted from the results of release tests with sample material.

Edge preparation for stainless steel articles

The procedure for preparing the edges of stainless steel test specimens
which have been cut from larger surfaces or articles involves appropriate
polishing. For example, the stainless steel surface may be polished under
water using SiC 1 200 paper to round off the edges without damaging the
adjacent surface. After polishing, the article must be washed with special
care so that no contaminants (such as metal particles) are left on the surface
of the sample. Finally, the sample should be left for at least 24 hours in a
clean and dry area so that the passive layer can re-form naturally.

Test conditions
The Guidelines issued by the JRC on testing conditions for kitchenware
articles (Beldi et al., 2021) specify the testing time and temperature for a
wide variety of kitchenware articles.

C. Food processing appliances

This applies to articles such as coffee makers, juicers, dispensing equipment,
electric kettles and meat mincers, as well as accessories and industrial
equivalents.

Test conditions
The appliances (or their component parts reasonably likely to be in contact
with food) should be tested under conditions of use according to the
instructions of the manufacturers. If during its intended use the material
or article is subjected only to precisely controlled time and temperature
conditions in food processing equipment, either as part of food packaging
or as part of the processing equipment itself, testing may be done using the
worst foreseeable contact conditions that can occur during the processing
of the food in that equipment.
For hot beverage appliances, testing should be performed in accordance
with EN 16889 (CEN, 2016).

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Methods of analysis
Methods of analysis used for release testing of FCM and articles must
comply with the provisions of Annex III (Characterisation of methods of
analysis) of Regulation (EU) 2017/625. Laboratories performing analyses
must use validated methods for the determination of metals and other ele-
ments according to the guidelines and criteria specifically set out in the
EUR 24105 Guideline (Bratinova et al., 2009), as revised.

Scope
The methods for the determination of elements released from metals and
alloys into foodstuffs and simulants.

Principle
The concentration of an element in a foodstuff or food simulant is deter-
mined by an instrumental method of analysis that fulfils the performance
criteria described below.

Homogenisation and digestion of food samples

Food samples should be homogenised and digested with mineral acid
using an appropriate method, while avoiding any contamination or loss of
material.
When removing foodstuff from articles, abrasion of the tested surfaces
must be avoided, and only non-metal household utensils (plastic spoon,
wooden scraper) should be used.

Preparation of test specimens of materials or articles

See Pre-treatment of materials and articles.

Quality of reagents
All reagents and solvents must be of analytical quality, unless otherwise
specified.
Water must be distilled or deionised (Ph. Eur., 2022), or water of similar
quality must be used.

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Metals and alloys used in food contact materials and articles

Quality and preparation of analytical equipment

Test vessels and storage containers made of low-density polyethylene dis-
posable material or quartz shall be used. High-density polyethylene (HDPE)
is also acceptable, while polypropylene (PP) is acceptable after verification.
Fluoroplastics are recommended where necessary, but care should be taken
when using polytetrafluoroethylene (PTFE), because of reported inter-
actions with metals. Before using PTFE labware, tests should verify that
absorption of metals in their surface at the conditions applied is negligible.
NOTE: Quartz containers should always be used in preference to
glass. If the use of glassware cannot be avoided, it should be care-
fully decontaminated before use. Blank measurements should
verify effective decontamination.
All equipment used for the preparation and execution of immersion exper-
iments should be acid cleaned with 10% HNO3 for a minimum of 24 hours
and then carefully rinsed with ultra-pure water before use to minimise the
risk of contamination of metals. Finally, the equipment must be dry when
used.

Instruments
NOTE: Analytical instruments and equipment are specified only
when necessary; otherwise, standard laboratory equipment may be
used.
Appropriate analytical methods should be employed, using instruments
such as:
• flame atomic absorption spectrophotometer (FAAS)
• graphite furnace atomic absorption spectrophotometer (GF-AAS)
• inductively coupled plasma atomic emission spectrometer (ICP-AES,
ICP-OES)
• inductively coupled plasma mass spectrometer (ICP-MS).
Other methods may be used, such as polarography, specific electrodes, etc.
providing that the analytical performance described below is achieved as
far as possible.

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Blank tests
A blank test must be performed to determine the initial concentration of the
element in the homogenised/digested foodstuff or simulant prior to contact
with the material or article under study. A blank test must be carried out
for each series of tests.

Analytical performance requirements

For the determination of metallic elements in foodstuffs or food simulants,
laboratories must use a validated analytical method that fulfils the perfor-
mance criteria indicated below, whenever possible.
The LOD is defined as the concentration of the element in the blank sample
that gives a signal equal to three times the background noise of the instru-
ment.The LOQ is defined as the concentration of the element in the food-
stuff or simulant that gives a signal equal to six times the background noise
of the instrument.
As far as possible:
1. LOD < 1/10 SRL
2. LOQ < 1/5 SRL
3. Recovery rate from 80 % to 120 %
4. The within-laboratory standard deviation for repeated analysis of a
reference or fortified material, under conditions of reproducibility
(intermediate precision), should not exceed the level calculated by the
Horwitz Equation (see Table 3).

Table 3. Predicted value for within-laboratory relative standard deviation (RSD),

under conditions of reproducibility, depending on concentration (Bratinova et al.,
2009)

Analyte % Analyte ratio Unit RSD (%) predicted

0.01 10-4 100 mg/kg 8.0
0.001 10-5 10 mg/kg 11.3
0.0001 10-6 1 mg/kg 16.0
0.00001 10-7 100 μg/kg 22.6

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Metals and alloys used in food contact materials and articles

5. Specificity: as far as possible free from matrix and spectral interferences

The Guidelines for performance criteria and validation procedures of ana-
lytical methods used in controls of FCM (Bratinova et al., 2009) should be
taken into account.

Measurements and reporting

The analytical results for test specimens sampled (see Sampling of materials
and articles) and tested for release in a foodstuff or food simulant, with the
measurements corrected for recovery, should be reported in mg Me/kg or
mg Me/dm2, with their expanded uncertainty and the analytical method.
A test specimen can be considered compliant when the concentrations of
any released elements (or the average concentration, in the case of replicate
instrumental measurements of the same test specimen solution after the
release testing) do not exceed the corresponding SRLs, taking into account
the expanded uncertainty of the measurements (see Calculation of specific
release).
Usually, more than one specimen of the same sample is tested (see Sampling
of materials and articles). The sample is considered compliant only if all the
test specimens of the sample are compliant.
In the case of single-use materials or articles, the results after the first
release test are used for the compliance statement.
In the case of repeated-use materials or articles, the results after the third
release test are used for the compliance statement. Additionally, the sum
of the results of the first and second release tests should not exceed seven
times the SRL (see Testing release from materials and articles into food
simulants, Articles for repeated use).
For articles that cannot be filled and for which it is impractical to estimate
the ratio of surface area to the amount of foodstuff in contact with it, the SR
is calculated according to the rules set out in Annex I. The corresponding
envelope volume must be reported.
For articles that consist of separate parts (including accessories) and for
which the surface area to volume ratio is not known for the assembled

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article, the total mass of any given released element must be calculated
by adding all the release values from the individual parts that come into
contact with food. This total mass of each released element must be con-
verted into mg/kg food by taking into account the real amount of foodstuff
coming into contact with the assembled article.

Examples:
Mincer / meat slicer / espresso machine

For silver or silver-plated cutlery, a reduction factor may be applied to the

SR of silver when justified (see Annex II).

Calculation of specific release

When the foodstuff or food simulant used for the release test contains the
element under investigation (see Release testing into foodstuffs, Natural
metal content of the foodstuff ), the original metal content must be sub-
tracted from the result of the release test.
SR = C1 – C0
where:
• SR is the concentration of the element that is released from the metal
or alloy into the foodstuff/food simulant, expressed in [mg Me/kg
food] or in [mg Me/dm2];
• C1 is the concentration of the element in the foodstuff/food simulant
after contact with the metal/alloy, expressed in [mg Me/kg food] or
in [mg Me/dm2]; and

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Metals and alloys used in food contact materials and articles

• C0 is the concentration of the element in the foodstuff/food simulant

before contact with the metal/alloy, expressed in [mg Me/kg food] or
in [mg Me/dm2].
NOTE: The measurement uncertainty of the release test result must
be taken into account to assess compliance.

Example:
Assuming
C0 = 2.0 mg Me/kg, u(C0) = 0.4 mg Me/kg
C1 = 8.0 mg Me/kg, u(C1) = 1.6 mg Me/kg
where u(C1) and u(C0) are the respective standard measurement uncertain-
ties, one gets:
SR = C1 – C0 = 8 - 2 = 6 mg Me/kg

where U(SR) is the expanded uncertainty, calculated using a coverage

factor (k) of 2, and applying the law of uncertainty propagation according
to BIPM (2008).
The final result should be reported as
SR = 6.0 ± 3.3 [(k=2) or (95%)] mg Me/kg.
This approach is also applicable when C0 and C1 are expressed in mg
Me/dm2.* The final result should then be multiplied by 6 to obtain a result
expressed in mg Me/kg.

* Applicable for articles described in section Materials and articles at the end-use level
that cannot be filled other than A.

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How to check compliance

The Eurachem guide (Williams and Magnusson, 2021) defines the four
cases presented in this figure:

Case A represents a result that is beyond any reasonable doubt below the
release limit (SR + U < SRL), hence the results would be considered as
compliant.
Similarly, case D represents a result that is beyond any reasonable doubt
above the release limit (SR - U > SRL), hence the result would be considered
as non-compliant.
The assessment of whether the results for cases B and C comply with the
release limit depends on whether it is necessary to demonstrate compliance
or non-compliance of materials and articles. For the former, the conserva-
tive approach (intended to protect the consumer) would consider cases B and
C as non-compliant. For the latter, to provide evidence of non-compliance
beyond reasonable doubt, only case D would be considered non-compliant,
so cases B and C would be compliant.

Calculating the SR for articles as defined in Annex I

The calculation is described in Annex I.

References
Beldi G, Senaldi C, Robouch P, et al. Testing conditions for kitchenware articles in contact
with foodstuffs: Plastics, Metals, Silicone and Rubber. EC JRC, JRC125894; 2021.
Bratinova S, Raffael B, Simoneau C. Guidelines for performance criteria and validation
procedures of analytical methods used in controls of food contact materials. EUR 24105

219
Metals and alloys used in food contact materials and articles

EN. EC JRC, JRC53034; 2009 [available at https://publications.jrc.ec.europa.eu/repository/

handle/JRC53034, accessed 25 Nov 2022].
Bureau International des Poids et Mesures (BIPM, with IEC, IFCC, ILAC, ISO, IUPAC,
IUPAP, OIML). Guide to the expression of uncertainty in measurement, JCGM
100:2008, GUM 1995 with minor corrections. September 2008 [available at https://www.
bipm.org/documents/20126/2071204/JCGM_100_2008_E.pdf/cb0ef43f-baa5-11cf-3f85-
4dcd86f77bd6, accessed 25 Nov 2022].
CEN. Food hygiene – Production and dispense of hot beverages from hot beverage appli-
ances – Hygiene requirements, migration test. Ref: EN 16889:2016.
European Parliament. Regulation (EC) No 2023/2006 of 22 December 2006 on good man-
ufacturing practice for materials and articles intended to come into contact with food. Offi-
cial Journal of the European Union 2006;49:75-78.
EC. Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and
articles intended to come into contact with food. Official Journal of the European Union
2011;54:1-89.
European Pharmacopoeia (Ph. Eur.). Deionised water R prepared by distillation with a
resistivity of not less than 0.18 MΩ·m determined at 25 °C. Ph. Eur. 11th Edition. Stras-
bourg, France, Council of Europe, 2022.
Souci SW, Fachmann W, Kraut H. Food Composition and Nutrition Tables. 8th edition.
Stuttgart: Wissenschaftliche Verlagsgesellschaft mbH; 2016.
Williams A, Magnusson B, editors. Eurachem/CITAC Guide: Use of uncertainty informa-
tion in compliance assessment. 2nd Edition. 2021 [available at www.eurachem.org/images/
stories/Guides/pdf/MUC2021_P1_EN.pdf, accessed 25 Nov 2022].

220
Annex I – Methods for measurement
of articles for which it is impractical to
estimate the ratio of surface area to the
amount of foodstuff in contact with it

This annex describes a method for calculating the foreseeable mass of

foodstuff in contact with articles from the section Articles for which it is
impractical to estimate the ratio of surface area to the amount of foodstuff
in contact with it, such as forks, brushes, etc.
The measurement of the surface area of a utensil is complex and is not
objectively linked to the consumer’s exposure. The following method pro-
vides conventions to be used for a direct and simple calculation of the SR in
mg/kg. It defines a rectangular cuboid with three dimensions (X = depth,
Y = width, Z = height) that encloses a space called the ‘envelope volume’.
The envelope volume is equivalent to the amount of food in contact with
the material and therefore relates to the consumer’s exposure.
This method deviates from the method currently described in European
Regulation (EU) No 10/2011 on plastic materials and it is proposed as
more appropriate for a number of utensils whose surface area is not corre-
lated with the amount of food in contact with it, and therefore consumer
exposure.

Measurements for the calculation of the

envelope volume of the utensil
In order not to drastically underestimate the contact volume for articles
with small dimensions along one or more of the axes, the minimum value
that can be assigned to each axis (X, Y and Z) is 5 cm. Each value below
5 cm will be rounded to 5 cm.

221
Metals and alloys used in food contact materials and articles

Beyond the minimum value of 5 cm, the length of each axis shall be meas-
ured and expressed in increments of 1 mm.

Determination of dimensions along the X, Y and Z axes

The figure above illustrates the three-dimensional envelope volume, where

the Z axis represents the height of the utensil, the X axis its depth and the
Y axis its width (Y).
Measure the value of the total height (Htotal) for the utensil using a gauge
(e.g. Vernier calipers) with a precision of 1 mm. The height shall be estab-
lished by measuring in a straight line along the centreline of the utensil.

Remark
If it is not clear what points should be used to determine the height mea-
surement, the utensil can be suspended (i.e. allowed to hang freely from the
highest point of the handle and then lowered until it touches a horizontal
surface e.g. a desktop). The height is then measured from the highest point of
the utensil perpendicular to the horizontal surface.
Then determine what portion of the total height (Htotal) of the utensil is
assigned, respectively, to the handle (Hhandle) and to the part necessarily in
contact with food (Hn).
Measure the length of the handle (Hhandle) using the gauge. If the handle is
made of metal and it is not clearly separate from the rest of the article, it is
assigned a default measurement of 1/3 of total height.

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 RELEASE TESTING OF FCMs AND ARTICLES MADE FROM METALS AND ALLOYS

Afterwards measure the depth (along the X axis) and the width (along the
Y axis) parallel to the horizontal surface using the same orientation of the
utensil as described above.
Calculate the height (Z) for defining envelope volume of the utensil as
shown in the following diagram and examples defining the height (Z) of
utensils:

Source: German Federal Institute for Risk Assessment (BfR)

223
Metals and alloys used in food contact materials and articles

Examples:

If there is a metallic decorative element between the functional part and

the handle or if the metallic decorative element is part of the handle and
is in contact with the functional part, this decorative element shall not be
taken into account when measuring the handle.

Deviation from the aforementioned process

Articles that cannot be filled may have a shape or may be used in a way that
makes them unsuitable for the aforementioned calculation process.

Examples:

In such cases an appropriate adaption of the calculation is necessary. This

has to be mentioned in the report along with a justification of the deviation.

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 RELEASE TESTING OF FCMs AND ARTICLES MADE FROM METALS AND ALLOYS

Calculation of the envelope volume

Once the rectangular cuboid has been constructed, calculate the envelope
volume as follows:
Envelope volume = X × Y × Z (cm3)
If any of the values is below 5 cm, it shall be rounded to 5 cm.

Determination of the reference mass (RW)

Determine the reference mass with respect to the envelope volume using
the following formula:
RW (kg) = Envelope volume (cm3)/1000

Examples:
• potato masher: 16.0 × 9.5 × 8.7 = 1322 → reference mass = 1.322 kg
• skimmer: 5 × 14.2 × 18.0 = 1278 → reference mass = 1.278 kg
• small ice cream scoop: 5 × 5 × 12.8 = 320 → reference mass = 0.320 kg

Determination of the released mass of a specific

element
Immerse the article up to the height of Z in a known volume of food sim-
ulant at the temperature and for the duration recommended in Chapter 3.
This volume is not necessarily the same as the envelope volume. It may be
larger (depending on availability of glassware sizes) or smaller (to maxim-
ise the concentration and therefore reduce the practical LOD) for reasons
of laboratory practice. Nevertheless, whenever possible, large volume devi-
ations should be avoided. If in the experimental set-up the simulant does
not cover the article’s surface up to the level of the calculated Z, appropriate
considerations should allow the relative contribution from the handle to be
added to the release (if made of the same material).

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Metals and alloys used in food contact materials and articles

Once the specific element has been released and its concentration in the
food simulant has been measured, calculate the released mass of the spe-
cific element.
Released mass (M) = V × C
where:
• V is the volume of simulant used, expressed in L
• C is the concentration of the element in the food simulant after
contact with the metal/alloy, expressed in [mg Me/L].
For consideration of the original metal content in the foodstuff or food
simulant, the rules laid down in ‘calculation of specific release (SR)’ apply.

Determination of the specific release

As a general rule:
SR = M/RW
where → SR is the concentration of the element that is released from
the metal or alloy into the food simulant, expressed in [mg Me/kg food
simulant].

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 RELEASE TESTING OF FCMs AND ARTICLES MADE FROM METALS AND ALLOYS

Annex II – Correction factor applied

when comparing release test results for
cutlery made from silver or silver-plated
cutlery with release limit for silver

Recent data from official control laboratories have shown that the release
of silver ions from cutlery made from silver or silver-plated cutlery tested
with citric acid under conditions for hot use (Beldi et al., 2021) may exceed
the release limit set for silver. Furthermore, testing under these conditions
does not adequately represent real use conditions and consumer exposure.
After considering the following arguments:
a. The analysis of silver in real food is challenging and often error-prone,
possibly leading to results that underestimate the release. This may
account for the absence, to date, of any reliable comparison between
silver release into food simulants and into real food. Therefore, it seems
more appropriate to test with citric acid as a simulant. However, as tests
using citric acid simulant at high temperatures tend to overestimate
(based on available data) the release of silver ions from silver compared
to worst foreseeable real use, the test result may have to be corrected.
b. Hot served acidic food represents only a small fraction of the daily food
consumption. Even though there are no reliable data available on the
consumption of hot acidic food with cutlery, it is safe to assume that
the amount of that particular type of food is less than the overall food
consumption.
c. Cutlery made of silver is rare and precious and therefore predomi-
nantly reserved for use on special occasions – a period ranging from a
few special or red-letter days (celebrations, holidays) per year to once
or twice a week (e.g. at the weekend). A factor derived from this time-

227
Metals and alloys used in food contact materials and articles

frame could vary from 3.5 (a weekend, twice a week) or 7 (once a week)
to as high as 365 (use only once a year). Taking into consideration only
the highest possible frequencies of use (e.g. once or twice a week) an
average factor of 5 would result.
d. WHO considered 0.39 mg/person/day as the NOAEL, which was also
taken into consideration by EFSA. The SRL for silver was derived based
on intake data using criterion 3 (i) of the criteria for establishing SRLs,
leading to an SRL of 0.08 mg/kg (which would contribute to 1/5th of the
NOAEL). Considering new analytical data for cutlery which indicate
that it is not in every case feasible to comply with the limit set, it may
be appropriate to take technically feasible levels (ALARA) into account.
However, at the present time, there are insufficient data to establish an
SRL based on ALARA.
It was concluded that a correction factor to be applied to the test results for
cutlery made from silver or silver-plated cutlery is justified.
Therefore:
For cutlery made from silver or silver-plated cutlery the SR can be cor-
rected by a factor. The correction factor is set to 5.
The correction factor shall be applied in accordance with the following
rules.
A correction is only applicable for the release of silver ions from cutlery
made from silver or silver-plated cutlery tested as in food serving imple-
ments for cold/ambient or hot use (FSI/CAH1) of the JRC guideline with
citric acid as simulant.
For silver-plated cutlery the correction can only be applied to items that
comply with the requirements of international standard ISO 8442-2.
The factor is only applicable to silver or silver-plated cutlery labelled in
accordance with Article 15 1(b) of Regulation (EC) No 1935/2004 as not suit-
able for food preparation or cooking, and not for a daily use. As an example
the label could be: ‘This cutlery is intended for food serving and eating pur-
poses, not for cooking or food preparation. Due to specific characteristics
of silver, it is recommended not to use silver articles on a daily basis.’

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 RELEASE TESTING OF FCMs AND ARTICLES MADE FROM METALS AND ALLOYS

The release test results shall be divided by the correction factor prior to
comparison with the release limit.

References
Beldi G, Senaldi C, Robouch P, et al. Testing conditions for kitchenware articles in contact
with foodstuffs: Plastics, Metals, Silicone and Rubber. EC JRC, JRC125894; 2021.
European Parliament. Regulation (EC) No 1935/2004 of the European Parliament and of
the Council of 27 October 2004 on materials and articles intended to come into contact
with food and repealing Directives 80/590/EEC and 89/109/EEC. Official Journal of the
European Union 2004;47:4-17.
ISO. Materials and articles in contact with foodstuffs – cutlery and table holloware – Part 2.
Requirements for stainless steel and silver-plated cutlery. Ref: ISO 8442-2:1997.

229
 Following the adoption of Council of Europe
Resolution CM/Res(2020)9, this revised technical
guide aims to ensure the safety and suitable
quality of food contact materials and articles
made from metals and alloys and is the result of a
comprehensive review by the European Committee
for Food contact materials and articles (CD-P-MCA).
The second edition reflects scientific opinions,
relevant research from national risk assessment
bodies and a concerted consultation of stakeholders;
it features modified safety data concerning specific
release limits (SRLs) for chromium, manganese,
thallium and a new section on zirconium and general
recommendations for release testing. The updated
methods for the measurement of certain articles
facilitate the calculation of specific release for control
laboratories.
This guide assists regulators and business operators
in applying harmonised technical standards across
Europe, in line with the mission of the European
Directorate for the Quality of Medicines & HealthCare
(EDQM), Council of Europe, of working towards
better health for all.

Free download at
http://freepub.edqm.eu/

ENG
www.edqm.eu The Council of Europe is the continent’s leading human rights
organisation. It comprises 46 member states, including all members of the
European Union. The European Directorate for the Quality of Medicines
& HealthCare (EDQM) is a directorate of the Council of Europe. Its m
­ ission
is to contribute to the basic human right of access to good quality
medicines and healthcare and to promote and protect public health.

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