In November 2015, The French General Directorate of Competition, Consumer Affairs and Fraud Control (DGCCRF) has published a methodological document (DM/4B/COM/001) for metals and alloys intended to come into contact with foodstuffs. The document supersedes requirements on metal and alloy FCMs in DGCCRF NI No.2004-64 on 1 January 2016.

In the document, food contact metals and alloys are categorised as below posing different requirements on metals, including definitions, metal proportion, hazardous elements, migration limits, conditions of migration test (selection of stimulants, temperatures and period).

1. Non coated stainless steels

2. Aluminium and aluminium alloys

a. Coated

b. Non coated

3. Steel for packaging

a. Non coated steel

b. Tin coated steel

c. organic coated steel

4. Non coated steel not for packaging

5. Coated steel and stainless steel not for packaging

a. Metallic coated

b. organic coated

6. Non alloyed cast iron

a. Non coated or metallic coated

b. organic coated

7. Tin and tin alloys

8. Zinc and zinc alloys

9. Metal and metal alloys with other various coating

It does not apply to enamelled materials, those having an inorganic coating or mineral-organic hybrid coating (such as "sol gels" coatings).

Compared with DGCCRF No.2004-64, the main changes: an additional migration of 21 (23) heavy metals as per CoE Resolution CM/Res(2013)9. Requirement as below:

1. Specific release limit of metal and alloy components

2. Specific release limit of metals as contaminants

BACL advises: In EU, much more of recalled food contact materials are from China, however, the new French regulation on metal and alloy food contact materials are more widely and detailed compared with other member states to ensure the safety of you product.