New French Law for Food Contact Rubber and Pacifiers for Young Children

France publishes a new law – Order of August 5, 2020 – covering food contact rubber materials and articles and pacifiers for infants and young children.

Issued on August 11, 2020, the Order repeals and replaces Order of November 9, 1994 – rubber materials and articles in contact with foodstuffs, food products and drinks. The new law contains multiple important changes:

  • Clarification to the definition of rubber covers vulcanized thermoplastic elastomers, but not silicone elastomers
  • Lists of authorized substances for the manufacture of rubber materials and articles intended to come into contact with food and pacifiers for infants and young children updated
  • Restrictions and specifications for these authorized substances updated due to new scientific information, including specific migration limits (SMLs)
  • Certain rules for verifying the conformity of rubber materials and articles updated
  • Completely new requirement for declaration of compliance (Doc) added
  • Expresses overall migration limits (OMLs) and their requirements in one of two specifications:
    • ≤ 10 mg/dm² for 1) all articles 2) pacifiers for infants and young children and 3) gaskets, valves and valve elements where the ratio between the surface in contact with food and the volume is not known or specified
    • ≤ 60 mg/kg for 1) food contact materials and articles for infants and young children 2) bottle nipples (teats) and 3) gaskets, valves and valve elements where the ratio between the surface in contact with food and the volume is known or specified

Stakeholders should be aware the new law covers:

  • Food contact rubber materials and articles, rubber pacifiers for infants and young children, as well as intermediate materials and substances used in their manufacture
  • Bottle nipples (teats) and pacifiers for infants and young children that are made of elastomer or rubber when specifically mentioned in the law

For more information on the provisions within the new law, including specific migration levels, view SafeGuard 128/20.

Order of August 5, 2020 comes into effect on July 1, 2021, although food contact rubber materials and articles that comply with the previous Order and were placed onto the market before this date can continue to be sold until their stocks are exhausted.

SGS Toy & Juvenile Product Services

SGS offers a wide range of services to ensure that products comply with relevant standards for childcare articles and children’s equipment. They provide consulting, training, product development, testing, audit and inspection services to ensure that products comply with strict regulations worldwide, demonstrating the safety and quality of juvenile products being brought to the market.  Learn more about SGS’s Toy & Juvenile Product Services. 

 

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For further information contact:

Hingwo Tsang

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