November 2025



Neuigkeiten aus Europa

ECHA announced that on 5 November 2025, 1,1'-(ethane-1,2-diyl)bis[pentabromobenzene] (Abbreviation: DBDPE) was included as a member of the SVHC Candidate List.

On 27 June 2025, the European Chemical Agency (ECHA) launched a 45-days public consultation on the substance, 1,1'-(ethane-1,2-diyl)bis[pentabromobenzene] (DBDPE), as a new potential Substance of Very High Concern (SVHC) with specifics shown in the table below.

After further discussion within ECHA’s Member State Committee, DBDPE was concluded to be a member of the SVHC Candidate List on 5 November 2025.

The number of SVHCs on the Candidate List is updated to 251 entries.

Details of this new SVHC candidate list’s member are summarized in the table below.

Substance

EC no.

CAS no.

Reason

Usage

1,1'-(ethane-1,2-diyl)bis[pentabromobenzene]

(Abbreviation: DBDPE)

284-366-9

84852-53-9

vPvB* (Article 57e)

- Formulation of flame retardants

- Thermoplastics in various sectors, including:

-Electronic and electrical components and electronic enclosures

- Construction (building, roofing)

- Automotive (e.g. wires and cables)

- Formulation of adhesives, sealants, coatings and inks

- Wood plastic composite

- Foam used in construction

*Remark:

VPvB = very Persistent and very Bioaccumulative

Manufacturers and importers should take note of DBDPE and its potential and current use in their processes or products to plan accordingly.

The European Commission adopted Delegated Regulation (EU) 2025/1482, amending Regulation (EU) 2019/1021 on Persistent Organic Pollutants. It sets updated unintentional trace contaminant limits for certain polybrominated diphenyl ethers in mixtures and products, with thresholds varying by material source (virgin or recycled) and product type.

The measure takes effect from 17 November 2025.

Polybrominated diphenyl ethers (PBDEs) are a group of brominated flame retardants historically used in plastics, textiles, electrical and electronic equipment, and other consumer products. They persist in the environment, can bioaccumulate in living organisms, and pose risks to ecosystems and human health.

The European Commission adopted Delegated Regulation (EU) 2025/1482, amending Annex I, Part A of Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs). This regulation introduces updated unintentional trace contaminant (UTC) limits for mixtures and articles containing PBDEs—including tetraBDE, pentaBDE, hexaBDE, heptaBDE, and decaBDE—based on their origin (virgin or recovered materials) and product type.

This amendment reflects updated science, detection capabilities, and EU obligations under international agreements, notably the Stockholm Convention on Persistent Organic Pollutants and the Protocol to the 1979 Convention on Long-range Transboundary Air Pollution. It supports the Union’s commitment to protect human health and the environment. Businesses must review their compliance strategies, particularly for recovered materials, toys, and childcare products subject to phased reductions through 2027.

The regulation recognizes that PBDEs in the EU market are now found predominantly in articles or mixtures manufactured from recovered materials. To manage technical feasibility and allow progressive adaptation by industry, differential UTC limits are applied depending on whether the product contains recovered material and whether it falls into sensitive categories such as toys and childcare products.

1. Requirement

Unintentional Trace Contaminant Limits (sum of tetra-, penta-, hexa-, hepta-, and decaBDE):

Included Under Requirement

Limit from

17 Nov 2025

Limit from

30 Dec 2025

Limit from

17 May 2027/30 Dec 2027

All mixtures and articles

10 mg/kg

-

-

Mixtures/articles of recovered material

500 mg/kg

350 mg/kg

200 mg/kg

(from

30 Dec 2027)

Toys and childcare products of recovered materials

500 mg/kg

350 mg/kg

10 mg/kg

(from

17 May 2027)

2. Exemptions

Food Contact Material (FCM) and articles are exempted from this regulation as these PBDEs, in principle, should not be present in these products according to Regulation (EU) No. 10/2011 on plastic materials and articles intended to come into contact with food.

3. Implementation

The restrictions on manufacturing, importing, exporting or using tetra-, penta-, hexa-, hepta-, and decaBDE start on 17 November 2025 (20 days after publication in the Official Journal).

The Executive Order of BEK nr 464 of 02/05/2025 issued by Denmark on 2 May 2025 is the implementation of the national ban on the import and sale of PFAS in clothing, footwear, and consumer‑use waterproofing agents for clothing and footwear.

Executive Order BEK nr 464 of 02/05/2025 took effect on 1 July 2025, with the actual enforcement of the ban commencing on 1 July 2026. This order represents the national ban on the import and sale of Per- and polyfluoroalkyl substances (PFAS) in clothing and footwear, and consumer-use waterproofing agents in Denmark. Main contents of this legal regulation are as follows:

1. Application scope

  • Clothing

  • Footwear

  • Waterproofing agents for clothing or footwear for private use

  • Textile products (personal protective equipment (PPE) excepted)

Exemption:

  • Recycled clothing or footwear

  • PPE

  • Medical devices

  • Transit cargo

2. Limit

  • Total fluorine content of 50 mg F/k

Note: Please note that the limit does not apply if the fluorine content comes from a substance that is not PFAS. That means the fluorine source may be inorganic chemicals. The Danish Environmental Protection Agency (EPA) may request documentation for this.

Effective 1 October 2025, the German Federal Institute for Risk Assessment implemented updates to its guidelines for nine categories of food contact materials and products. Eight recommendations were revised while one outdated recommendation was withdrawn. These adjustments aim to enhance consumer safety and align material standards with current scientific and regulatory developments.

The German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) revised several of its guidelines for materials and articles intended for contact with food. In total, eight existing recommendations have been updated, introducing stricter limits, new substance approvals, and updated testing methods. Additionally, one outdated recommendation has been withdrawn (without replacement).

Key changes include tighter migration limits for bisphenol A(BPA), new “not detected” requirements for acrylamide, expanded lists of permitted additives, and additional references to European Union (EU) regulations. The changes affect nine different material categories.

The intent of the revisions is to enhance consumer safety and align the guidelines with current regulatory and scientific developments. Parties should review the revisions for an understanding of the impact of the updates which became effective on 1 October 2025.

Main updates at a glance:

Recommendation

Previous Status

Key Changes (October 2025)

XIV – Polymer Dispersions

Last updated February 2022

• Added sodium hexametaphosphate to the list of permitted emulsifiers, with specific conditions.

• Introduced a new additive category (“Category 3”) with requirements for microfibrillated cellulose.

XV – Silicone

Last updated September 2024

• Footnote 7 adjusted to require compliance with Recommendation XXV on paraffins and waxes

XVII – Polyterephthalic Acid Diol Esters

Last updated July 2016

• New footnote 1 limiting Bisphenol-A- diglycidyl-ether content to ≤ 2%

• Explicit reference to EU Regulation 2024/3190 governing BPA and related bisphenols

XXX – Conveyor Belts from Gutta-Percha & Balata

Recommendation from 1984 still in place

• Withdrawal of the 1984 version with no replacement.

XXXVI – Paper and Board for Food Contact

Last updated August 2024

• Footnotes 8 and 9 changes for colorfastness testing, specifying EN 646 and EN 648 methods and rating requirements

• Acrylamide must be “not detected” (detection limit (DL) = 0.01 mg/kg) in final products

• Expanded list of specified materials and additives

• BPA migration limit tightened from 0.05 mg/kg to 0.01 mg/kg for recycled paper

• Added requirement for Mineral Oil Aromatic Hydrocarbons (MOAH) content

• Several footnote relocations and text changes, including Primary aromatic amines (PAAs)

XXXVI/1 – Cooking Paper, Hot Filter Paper, Filter Layers

Last updated August 2024

• Acrylamide “not detected” requirement introduced

XXXVI/2 – Paper/Paperboard for Baking Purposes

Last updated August 2024

• Acrylamide “not detected” requirement introduced

XXXVI/3 – Absorber Pads (Cellulose Fibers)

Last updated September 2019

• Acrylamide “not detected” requirement introduced

XLIV – Artificial Sausage Casings

Last updated November 2014

• Footnote 10 updated to require compliance with Recommendation XXV on paraffins and waxes

Neuigkeiten aus China

The latest standards for food contact coatings, GB 4806.10, and food contact silicone of GB 4806.16 in China have been published on 2 September 2025. The two mandatory standards will be implemented beginning 2 September 2026.

Two mandatory Chinese National Standards, food contact coatings, GB 4806.10, and food contact silicone, GB 4806.16, which were published on 2 September 2025, contain many changes.

  • GB 4806.10-2025 for food contact coatings replaced and repealed GB 4806.10-2016.

  • GB 4806.16-2025 for food contact silicone was divided from GB 4806.11-2016 which composited requirements for food contact rubber and silicone and had many updates. In 2023, GB 4806.11 was updated to the 2023 version which revised the rubber section only.

  • GB 4806.16-2025 for food contact silicone and GB 4806.11-2023 for food contact rubber replaced and repealed GB 4806.11-2016.

Please find the key revisions to these standards as follows:

Standard of Food Contact Material

Section

Updated Requirement

Previous Requirement

Note

GB 4806.10 (food contact paints and coatings)

Scope

This standard applies to paints and coatings used in food contact applications.

This standard applies to paints and coatings used in food contact applications.

This standard does not apply to paper paints and coatings.

“Paper paints and coatings” are additives for paper and paperboard materials and products. The finished coated paper/board products shall fulfill the requirements in GB 4806.10 (food contact coating) and GB 4806.8 (food contact paper/board).

Parameter of “Potassium permanganate consumption” and “Heavy metal”

Test condition of high temperature (boiling for 0.5h, followed by room temp. for 24h) is updated to cookware only.

Test condition of high temperature (boiling for 0.5h, followed by room temp. for 24h) is for cookware and drinking utensils.

/

Parameter of “Primary Aromatic Amines (PAA) migration”

New requirement.

/

For coatings containing aromatic isocyanates and azo colorants only.

Migration test

Added special requirement for food contact coatings on metal can (including can body, lid, pull ring, etc.).

/

For overall migration using 4% acetic acid, if the specimen has changes in actual use, such as coating peeling, blistering, or metal corrosion, an inert substrate can be used for sample preparation before testing. If this method is not feasible, 10% ethanol can be used instead of 4% acetic acid. However, this principle does not apply to specific migration test.

Labeling

Remove the requirement of “coated material and product shall also list the material name of substrate and coating”.

In addition to complying with the provisions of GB 4806.1, the labeling shall also list the material name of substrate and coating.

/

GB 4806.16 (food contact silicone)

Parameter of “Potassium permanganate consumption” and “Heavy metal”

Test condition is updated to 60℃ for 2 h.

Test condition was 60℃ for 0.5 h.

/

Parameter of “Volatile matter”

New requirement.

/

Test method is included in Annex B of GB 4806.16-2025.

Migration test

Remove the special provision that “50% ethanol shall be used as the food simulant for oil foods”.

50% ethanol shall be used as the food simulant for oil foods.

Food simulants shall be selected in accordance with "National Food Safety Standard - General Rules for Migration Tests of Food Contact Materials and Articles" (GB 31604.1-2023).

In view of the revisions, it is important for interested parties to review to ensure the compliance of testing, labeling, etc. The two mandatory standards will enter into force beginning 2 September 2026.

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