July 1, 2023 Deadline Approaching for Filing Declaration of Interest for Certain Substances Used in Food-Contact Rubber

As previously reported, the German Federal Institute for Risk Assessment (BfR) overhauled its recommendations for food-contact rubber in 2021 (article available here). The three recommendations now applicable to rubber are:

• XXI: Commodities based on natural and synthetic rubber 
• XXI/1: Commodities based on natural and synthetic rubber in contact with food 
• XXI/2: Special consumer goods made of natural and synthetic rubber and of latices made of natural and synthetic rubber (formerly special category) 

Both BfR Recommendations XXI/1 and XXI/2 contain a Table 1 (list of rubbers and latices) and a Table 2 (not conclusively evaluated raw materials, additives, and processing aids). Substances will be deleted from the Tables 2 unless Declarations of Interest[1] to continue using the substances in question are submitted to the BfR prior to July 1, 2023. The next step would be to submit a petition to the BfR for those substances by a deadline of July 1, 2026, to maintain them on the recommendations. 

The rubber Recommendations are available on the BfR’s website. BfR Recommendation XXI indicates that BfR is also working on a fourth rubber Recommendation, BfR Recommendation XXI/3 (consumer goods made of cross-linked thermoplastic elastomers).

[1] The BfR refers to this as a “declaration of intent to apply”