BFR Recommendation XXI-1. Rubber Contact Food - EN
BFR Recommendation XXI-1. Rubber Contact Food - EN
BFR Recommendation XXI-1. Rubber Contact Food - EN
XXI/1. Commodities based on natural and synthetic rubber in contact with food
As of 01.04.2022
1. Preliminary remarks
Recommendation XXI. Consumer goods based on natural and synthetic rubber must be ob-
served.
a) The majority of articles made of natural and synthetic rubber intended for food contact
does not come into contact with food with its entire surface and for a long period of time,
but mostly only with a part of the surface and also only for a limited time. These special
conditions of use must be taken into account in the assessment. Accordingly, the test
conditions for determining the migration of substances from consumer goods into food
or food simulants are to be oriented to the practical use of the consumer goods.
According to the different conditions of use that occur in practice, the consumer goods
made of natural and synthetic rubber are divided into four categories:
b) In order to characterise the individual categories, a few consumer goods are listed as
examples in each case. Materials and articles which may come into contact with food-
stuffs at different contact times have been assigned to the category with the longer con-
tact time. Certain test conditions are assigned to the categories. If the actual conditions
of use in a specific case differ significantly from the test conditions, these must be
adapted to the respective conditions of practical use.
c) The specific migration test shall be carried out in the foodstuff, by derogation the simu-
lants listed in 2.5 may be used. If it is found that the performance of the tests causes
physical or other changes in the sample which do not occur under the worst foreseeable
conditions of use of the material or article under test, the migration tests shall be per-
formed under the worst foreseeable conditions of use under which these physical or
other changes do not occur.
If a test is carried out in the foodstuff milk, it must have a fat content of 3.5 %.
The assignment of simulants to foodstuffs shall be made in accordance with Table 2 in
Annex III to Regulation (EU) No 10/2011, with the exception of tests where water is re-
quired.
d) If migration guide values are given, the results of migration experiments must be con-
verted, if necessary, taking into account the actual contact area and food quantity.
If such a calculation is not possible, assume a surface-to-volume ratio of 1 dm²/200 ml.
Page 1 of 14
2. Categories and test conditions
Whether the specified test conditions are sufficient for longer contact and/or at higher
temperatures can be checked via the Arrhenius correlation, which describes the depend-
ence of the migration rate of substances from polymers on temperature. From this, the
simplified rule can be derived that an increase in temperature by 10 °C leads to a dou-
bling of the migration rate.1
For testing times of 24 hours or less, compliance with the temperature in the food or food
simulant must be checked.
2.1 Category 1
2.1.1 Definition
This category includes commodities that come into contact with food for longer than 24
hours up to several months when used as intended.
Examples:
1. storage containers
2. container linings
3. sealing rings for cans, jars, bottles and the like
4. stoppers and caps for bottles
2.2 Category 2
2.2.1 Definition
This category includes commodities that come into contact with the food for a maxi-
mum of 24 hours when used as intended.
Examples:
1. hoses for conveying food
2. sealing rings for pressure cookers, hoses for coffee machines
3. lid seals, e.g. for milk cans
4. valve balls
2.2 Category 3
2.3.1 Definition
This category includes consumer articles that come into contact with the food for a
maximum of 10 minutes during intended use (short-term contact).
Examples:
1. Liners in milking systems
2. Milking machine hoses
3. Seals for milk processing machines
4. Diaphragms, pistons, fittings and the like
5. Pump stators
6. Roller covers for greasy food
7. Conveyor belts for fatty foods
8. Gloves, aprons worn during the processing of foodstuffs
1
This context can in principle be used to assess whether the test conditions specified in the individual categories
cover the worst foreseeable conditions of use.
Page 2 of 14
2.3.2 Migration testing
Test conditions: 10 minutes at 40 °C
2.4 Category 4
2.4.1 Definition
This category includes commodities which, when used as intended, are only used un-
der such conditions that no transfer to the food is to be expected. This applies in partic-
ular if the article only comes into contact with the food at temperatures up to room tem-
perature and only for a very short time and/or only with a very small surface area and
cannot be classified in categories 1 to 3.
Examples:
1. Conveyor belts and roller covers for solid foodstuffs, e.g. harvested goods
2. Suction and pressure lines for solid foodstuffs, e.g. for filling and emptying ship
tanks, wagons and the like
3. Seals for pipelines, pumps, taps and angle seat valves and the like for liquid food-
stuffs
deionised water
10 % ethanol by volume
20 % ethanol by volume
3 % acetic acid by weight
50 % ethanol by volume
Poly(2,6-diphenyl-p-phenylene oxide), particle size 60-80 mesh,
Pore size 200 nm
any vegetable oil with less than 1 % unsaponifiable matter.
Page 3 of 14
2.6 Testing migration from commodities for repeated use
If the material or article is intended to come into repeated contact with foodstuffs, the
migration tests shall be carried out three times on the same sample, each time using a
different portion of the food (simulant). Conformity shall be checked on the basis of the
migration value found in the third test.
If there is conclusive evidence that the migration value does not increase in the second
and third tests and the migration benchmarks are not exceeded in the first test, no fur-
ther testing is required.
3. Substances for the manufacture of commodities from natural and synthetic rubber
or from the corresponding latices
Only the substances listed in the Annex to Recommendation XXI and in Table 2 may be
added to the raw materials for the manufacture of the finished products. The quantities
indicated (calculated on the finished products) must be complied with2.
If the starting materials are pre-crosslinked or pre-stabilised with anti-ageing agents, only
the substances listed in the Annex to Recommendation XXI and in Table 2 may be added
for this purpose.
All substances used shall be considered in their total quantity.
2 In the case of commodities of non-uniform composition, the term "finished product" is used in this Recommenda-
tion to mean the part of the finished commodity consisting of rubber, and this in turn only to the extent that it
comes into direct contact with foodstuffs during the foreseeable use of the material and article.
Page 4 of 14
3.1.2 Rubber dispersions (latices)
Dispersions of the rubber types listed in Table 1 may be used as starting materials.
The latices may contain the excipients listed in the respective applicable version of
Recommendation XIV (Polymer Dispersions) in the quantities listed therein.
Within Table 2, columns have been introduced for the individual categories. Based on
the assignment, it can be read for each substance for which category it can be used. The
use for category 1 (long-term contact) basically also includes the shorter contact of cat-
egories 2-4. In these cases, the cells have been linked in Table 2. Conversely, however,
substances that are only recommended in categories 2-4 may not be used in consumer
articles for prolonged contact. Therefore, in these cases, the cells of the categories for
which the substance must not be used have been crossed out.
For the rubbers and latices listed in Table 1, only the substances listed in Table 2 and in Ta-
ble 1 of the Annex to Recommendation XXI may be used as starting materials (monomers).
Page 5 of 14
Table 1: List of rubbers / latices
a Franck, R. Plastics in food traffic. Cologne: Carl Heymanns Verlag - loose-leaf edition, Part B II XXI: Investigation of rubber consumer goods, ISBN: 978-3-452-16045-4.
Page 6 of 14
Table 1. rubbers / latices (continued)
FCM substance no. Chemical name Comments Requirements/restrictions
3
Recommendation XXXV. "Copolymers of ethylene, propylene, butylene, vinyl esters and unsaturated aliphatic acids and their salts and esters".
4
Recommendation II. "Plasticizer-free polyvinyl chloride, plasticizer-free copolymers of vinyl chloride and mixtures of these polymers with other copolymers and chlorinated
polyolefins containing mainly vinyl chloride in the total mixture".
Page 7 of 14
Table 2: Not conclusively evaluated raw materials, additives and processing aids
For the use levels of the substances listed in Table 2, in addition to the limits specified in the category columns, sum use limits shall apply to
each of the substances marked (1), (2), (3), (4), (5) or (6)5:
(1) total max. 1.2 %
(2) total max. 3.0 %
(3) total max: 1.2 %
(4) total max. 0.05 %
(5) total max. 1.0 %
(6) total max. 1.0 %.
5
If several limitations are assigned to a substance, all of them must be observed. o-Tolylbiguanide may be used up to a maximum of 1 %. If other substances of group (1) are used, their sum must
not exceed 1.2 %. If substances of group (2) are also used, their sum must not exceed 3 %.
Page 8 of 14
Vulcanisation accelerator (continued)
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
Zinc-(N-N-pentamethylenedithiocarba-
0013878-54-1 (1) (2)
mate)
0014634-93-6 Zinc-N-ethylphenyldithiocarbamate Max. 0.4 % (1) (2)
0000097-74-5 Tetramethylthiuram monosulphide (1) (2)
The following guideline value for the release of zinc dibenzyldithiocarbamate must
0014726-36-4 Zinc dibenzyldithiocarbamate Max. 0.5 % (1) (2) be observed in consumer articles according to categories 1 - 4: 0.1 mg/kg elasto-
mer content.
0000137-26-8 Tetramethylthiuram disulphide (2) Maximum transfer into food or food simulant: 0.6 mg/kg
0000097-77-8 Tetraethylthiuram disulphide (2) Maximum transfer into food or food simulant: 0.6 mg/kg
0053880-86-7 Dimethyldiphenylthiuram disulphide (2)
0000120-54-7 Dipentamethylenethiuram tetrasulphide (2)
Consumer articles manufactured using caprolactam disulphide must be washed at
0023847-08-7 Caprolactam disulphide Max. 1.0 % (2) 90 °C for 1 hour. Regulation (EU) No 10/2011 sets a SML of 15 mg/kg for capro-
lactam.
0013074-29-8 Sodium ethylphenyldithiocarbamate
0000128-04-1 Sodium dimethyl dithiocarbamate
0000148-18-5 Sodium diethyl dithiocarbamate
Sodium diisopropyl dithiocarbamate Total max. 0.4 % (3)
Page 9 of 14
Vulcanisation accelerator (continued)
Cate-
CAS No. Chemical name Category 1 gory Category 3 Category 4 Requirements/restrictions
2
0000149-30-4 2-Mercaptobenzothiazole (4) (4) (5)
0000120-78-5 Dibenzothiazyl disulphide (4) (5) Maximum transfer of 2-mercaptobenzothiazole into food or food simulant: 2 mg/kg
0000155-04-4 Zinc-2-mercaptobenzothiazole (5)
Surface hardener
Cate-
CAS No. Chemical name Category 1 Category 2 Category 4 Requirements/restrictions
gory 3
Pentamethylene-ammonium-N-pen-
0000098-77-1 The two substances must not be detectable in the The test shall be carried out in accordance with section 2.5.2.2.6 of the publication
tamethylene-dithiocarbamate
finished product. indicated in footnoteFehler! Textmarke nicht definiert.
0005459-93-8 Cyclohexylethylamine
000111-92-2 Dibutylamine Restrictions according to 4.7 must be observed.
Accelerator activators
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
The total transfer of zinc according to 4.2 of this recommendation must be ob-
0001314-22-3 Zinc peroxide
served.
Anti-ageing agent
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
produced from the monomers
Phenol and/or methylphenols, reacted - Phenol (CAS: 000108-95-2)
with styrene or α-methylstyrene and/or (6) - Methylphenols (CAS: 000108-39-4, 000095-48-7, 000106-44-5)
olefins of chain length C3-C12 - α-Methylstyrene (CAS 000098-83-9)
- Olefins (C3-C12)
Mixture of 2,2'-methylene-bis-(4-methyI-
6-nonylphenol), about 2 parts, and 2,6- Consumer goods in the manufacture of which these anti-ageing agents are used
Not more than 0.3 % of the mixture (6)
bis-(2-hydroxy-3-nonyl-5-methylbenzyl)- must not come into contact with fatty foods.
p-cresol, about 1 part.
Bis(3,5-dimethyl-2-oxyphenyl)-isobu-
0033145-10-7 (6)
tane
Consumer goods in the manufacture of which these anti-ageing agents are used
0068442-68-2 Diphenylamine, styrolised (6)
must not come into contact with fatty foods.
N-phenyl-N'-(1,3-dimethylbutyl)-p-phe-
0000793-24-8 Max. 1.5 % Test see 4.9
nylenediamine
2-α-Methylcyclohexyl-4,6-dimethylphe-
0000077-61-2 Max. 1 %
nol
0026523-78-4
Purity requirements for tris(nonylphenyl)phosphite p. 76. Communication on the
(tris-
Tris-(monononyl and/or dinonylphenyl)- "Gesundheitliche Beurteilung von Kunststoffen im Rahmen des Lebensmittel- und
monononyl)00 (6)
phosphite Bedarfsgegenständegesetzes t", Bundesgesundheitsblatt 15 (1972) 139.
01333-21-7
Maximum transfer into food or food simulant: 30 mg/kg
(tris-dinonyl)
063231-60-7 Microcrystalline waxes Max. 3.0% in the finished product
Page 10 of 14
Antioxidants may also be used in mixtures with hard paraffins and micro-crystalline
008002-74-2 Paraffine waxes, provided that they comply with Part I, Sections A, B and C of the current
version of Recommendation XXV.
Processing aids
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
The total transfer of zinc according to 4.2 of this recommendation must be ob-
0000117-97-5 Pentachlorothiophenol, zinc salt Max. 0.3 %
served.
Polyethylene glycol, fatty alkyl ether Max. 2.0 % Limitation together with polyethylene glycol
0009006-24-0 Xylene formaldehyde resins cf. 4.8 of this recommendation
Melamine-resorcinol-formaldehyde
resins Max. 5.0 % Only as an adhesion promoter, cf. 4.8 of this recommendation
024969-11-7 Resorcinol-formaldehyde resins
Only natural and/or hydrogenated fats and oils of vegetable and/or animal origin,
but not blown oils and fats, may be used as raw material for the production of the
Faktice factice. Only aliphatic or cycloaliphatic secondary amines may be used as factica-
(unsaturated vegetable or animal tion regulators. The factication regulators must be fully reacted. Testing for ali-
Max. 20.0 %
oils reacted with sulphur, chlorosul- phatic and cycloaliphatic secondary amines shall be carried out in accordance with
phur or hydrogen sulphide) section 2.5.2.2.5 of the publication referred to in footnote Fehler! Textmarke nicht
definiert. to table 1. Other factice additives shall comply with this recommendation
in nature and quantity.
Lubricant and mould release agent
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
Alkyl sulphonates
Protective colloids, thickeners and plasticisers (Only for latices and rubber dispersions)
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4
0009003-19-4 Polyvinyl ether According to Recommendation XVI “Polyvinyl ethers”; Only for Latices
Alkali salts and amides of polymers
of acrylic acid, methacrylic acid,
crotonic acid, maleic acid, fumaric
acid, itaconic acid, vinylsulfonic acid
Page 11 of 14
Emulsifiers and dispersants (Only for latices and rubber dispersions, continued)
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
Alkyl(C10-C20)sulfonates
Alkyl-arylsulfonates
Alkyloxethylates
Alkyl oxethylates, sulphation pro-
ducts
Alkylaryloxethylates
Alkylaryloxethylates, sulphation pro-
ducts
Acyloxethylates
Acyloxethylates, sulphation pro-
ducts
Alkylphenyl polyglycol ethers
Alkyl polyglycol ethers
Condensation products of naphtha-
lene sulphonic acid sodium salt and cf. 4.8 of this recommendation
formaldehyde
Defoaming agent (Only for latices and rubber dispersions)
CAS No. Chemical name Category 1 Category 2 Category 3 Category 4 Requirements/restrictions
0000126-71-6 Triisobutyl phosphate
Precipitant (Only for latices and rubber dispersions)
Category
CAS No. Chemical name Category 1 Category 2 Category 3 Requirements/restrictions
4
0009003-09-2 Polyvinyl methyl ether
Organopolysiloxanes with methyl
0104780-78-1
groups, ethoxylated Insofar as they comply with Section I of the current version of Recommendation
Organopolysiloxanes with methyl XV “Silicones”, viscosity at 20 °C about 97 mPa s
groups, propoxylated
Page 12 of 14
Finished products
4.1 The total migration of substances from commodities in categories 1, 2 and 3 of this Rec-
ommendation into food simulants shall not exceed 10 mg/dm² of the commodity.6
4.2 The total transfer of zinc from finished products of categories 1, 2 and 3 shall not exceed
25 mg/kg food or food simulant.
4.3 The total transfer of aluminium from finished products of categories 1, 2 and 3 shall not
exceed 1 mg/kg food or food simulant.
4.4 A transfer of lead from finished products of category 1, 2 and 3 shall not be detectable
with a detection limit of 0.01 mg/kg food or food simulant. The test shall be carried out in
the first migration.
4.5 For consumer articles according to categories 1, 2 and 3 of this recommendation, the
release of N-nitrosamines must not be detectable with a sum detection limit of 1 μg/dm²
elastomer. The testing of the articles has to be carried out under the time and tempera-
ture conditions specified for the respective categories. Testing with deionised water must
not be omitted. The test shall be carried out in the first migration.
4.6 For consumer goods of categories 1, 2 and 3, the following also applies:
The extracts prepared according to the test specification 7 shall not contain primary aro-
matic amines classified as carcinogenic substances of categories 1A and 1B according
to Regulation (EC) No 1272/2008 on classification, labelling and packaging of sub-
stances and mixtures in a detectable amount. The detection limit is 0.002 mg/l. In total,
primary aromatic amines must not be detectable above 0.01 mg/l. Testing with deionised
water shall not be waived. The test shall be carried out in the first migration.
The amount of secondary N-alkyl-arylamines shall not exceed 0.25 mg/l in total.
4.7 For the release of secondary aliphatic and cycloaliphatic amines from consumer articles
of categories 1 - 3, a guide value of 5 mg/dm2 applies.
4.8 No more than 3 mg/l formaldehyde shall be detectable in the aqueous migrates prepared
according to the test specification.8
6 Tests have shown that 50 % ethanol by volume may be an overestimating simulant for milk in contact with rubber. It is there-
fore not mandatory to use it for milk with regard to the total migration test.
7
The examination shall be conducted in accordance with Section 4 of the publication indicated in footnoteFehler! Textmarke
nicht definiert. to table 1.
8
The test is carried out according to section 2.7.1 of the methods. In: Ostromov, H. Hofmann, W., 1978. examination of rubber
consumer goods. Berlin: Reimer, 31 (MvP Reports; 2/78).
Page 13 of 14
4.9 By way of derogation from the publication referred to in footnote 9, the components of
milking installations shall be pre-treated as follows before the migration test is carried
out:
For the 2nd step of sample pre-treatment, use an aqueous 0.25 wt.% nitric acid as clean-
ing solution. For teat rubbers, the rinsing processes shall be carried out according to Fig.
2 (see publication footnote9) to avoid rinsing shadows.
The time between pre-treatment and migration test is 60 ± 10 minutes.
The transfer of primary aromatic amines shall not exceed 0.05 mg/l for the entire
cluster.
After contact with milk or water at 40 °C for 10 minutes, the content of N-phenyl-N'-(1,3-
dimethylbutyl)-p-phenylenediamine in these liquids must not exceed 0.3 mg/l10.
4.10 Some of the substances listed in this Recommendation may cause an antimicrobial effect
in the finished product. However, no substances, including those listed in the Recom-
mendation, may be used in articles in accordance with this Recommendation for the
purpose of intentionally imparting antimicrobial activity to finished articles.
4.11 In order to prevent the risk of allergies, the soluble protein content of materials and arti-
cles made of natural rubber materials in accordance with this Recommendation, which
may also come into contact with the skin, shall be reduced to a minimum. In the case of
products manufactured from natural rubber latex, the materials and articles or their pack-
aging shall bear a statement to the effect that the product is manufactured using natural
rubber latex which may cause allergies. In the case of products made of natural rubber,
the materials and articles or their packaging shall bear the indication that the product has
been manufactured using natural rubber.
9
62nd Communication regarding "Untersuchung von Kunststoffen, sowie sie als Bedarfsgegenstände im Sinne des Lebensmit-
tel-, Bedarfsge-genstände und Futtermittelgesetzbuches verwendet werden", Bundesgesundheitsblatt, Gesundheitsfor-
schung, Gesundheitsschutz 50 (2007) 524.
10 The test shall be carried out in accordance with sections 6.1.1, 6.2.2 and 6.2.3. of the publication indicated in footnote a to
table 1.
Page 14 of 14