CONSUMER HEALTH PROTECTION COMMITTEE

COMMITTEE OF EXPERTS ON MATERIALS COMING INTO

CONTACT WITH FOOD

POLICY STATEMENT
CONCERNING

PAPER AND BOARD MATERIALS AND ARTICLES

INTENDED TO COME INTO CONTACT WITH
FOODSTUFFS
Version 4 12.02.2009
NOTE TO THE READER
The following documents are part of the Policy statement concerning paper and board
materials and articles intended to come into contact with foodstuffs:

Resolution ResAP (2002) 1 on paper and board materials and articles intended
to come into contact with foodstuffs

Technical document No. 1 - List of substances to be used in the manufacture of

paper and board materials and articles intended to come into contact with
foodstuffs (Version 3)

Technical document No. 2 - Guidelines on test conditions and methods of analysis

for paper and board materials and articles intended to come into contact with
foodstuffs (Version 3)

Technical document No. 3 - Guidelines on paper and board materials and articles,
made from recycled fibres, intended to come into contact with foodstuffs
(Version 2)

Technical document No. 4 - CEPI Guide for good manufacturing practice for paper
and board for food contact (prepared by CEPI)

Technical document No. 5 - Practical Guide for users of Resolution ResAP

(2002) 1 on paper and board materials intended to come into contact with
foodstuffs (Version 2)

The documents are available on the Internet website of the Partial Agreement in the Social
and Public Health Field:

www.coe.int/soc-sp

2
 Table of contents

Page

Resolution ResAP (2002) 1 on paper and board materials and articles intended
to come into contact with foodstuffs .......................................................................... 5

Technical document No. 1 - List of substances to be used in the manufacture

of paper and board materials and articles intended to come into contact with
foodstuffs (Version 3) ................................................................................................ 11

Technical document No. 2 - Guidelines on test conditions and methods of

analysis for paper and board materials and articles intended to come into
contact with foodstuffs (Version 3) ............................................................................ 79

Technical document No. 3 - Guidelines on paper and board materials and

articles, made from recycled fibres, intended to come into contact with
foodstuffs (Version 2) ................................................................................................ 87

Technical document No. 4 - CEPI Guide for good manufacturing practice for
paper and board for food contact (prepared by CEPI) ............................................... 109

Technical document No. 5 - Practical Guide for users of Resolution ResAP

(2002) 1 on paper and board materials intended to come into contact with
foodstuffs (Version 2) ................................................................................................ 127

3
4
 RESOLUTION RESAP (2002) 1 ON
PAPER AND BOARD MATERIALS AND ARTICLES INTENDED
TO COME INTO CONTACT WITH FOODSTUFFS

5
 RESOLUTION RESAP (2002)1 ON
PAPER AND BOARD MATERIALS AND ARTICLES
INTENDED TO COME INTO CONTACT WITH FOODSTUFFS
(adopted by the Committee of Ministers on 18 September 2002
at the 808th meeting of the Ministers Deputies)
The Committee of Ministers, in its composition restricted to the Representatives of
Austria, Belgium, Cyprus, Denmark, Finland, France, Germany, Ireland, Italy,
Luxembourg, The Netherlands, Norway, Portugal, Slovenia, Spain, Sweden,
Switzerland and the United Kingdom, member states of the Partial Agreement in the
Social and Public Health Field,

Recalling Resolution (59) 23 of 16 November 1959, concerning the extension of the

activities of the Council of Europe in the social and cultural fields;

Having regard to Resolution (96) 35 of 2 October 1996, whereby it revised the

structures of the Partial Agreement and resolved to continue, on the basis of revised
rules replacing those set out in Resolution (59) 23, the activities hitherto carried out
and developed by virtue of that resolution; these being aimed in particular at:

a. raising the level of health protection of consumers in its widest sense, including a
constant contribution to harmonising in the field of products having a direct or
indirect impact on the human food chain as well as in the field of pesticides,
pharmaceuticals and cosmetics legislation, regulations and practices governing, on
the one hand, quality, efficiency and safety controls for products and, on the other
hand, the safe use of toxic or noxious products;

b. integrating people with disabilities into the community; defining and contributing
to its implementation at European level of a model of coherent policy for people
with disabilities, which takes account simultaneously of the principles of full
citizenship and independent living; contributing to the elimination of barriers to
integration, whatever their nature, whether psychological, educational, family-related,
cultural, social, professional, financial or architectural;

Having regard to the action carried out for several years for the purposes of
harmonising their legislation in the public health field and, in particular, with regard to
paper and board materials and articles intended to come into contact with foodstuffs;

Considering that paper and board materials and articles intended to come into
contact with foodstuffs may, by reason of migration of paper and board constituents
to the foodstuffs, pose under certain conditions a risk to human health;

Emphasizing the fact that this resolution and the technical documents on paper and
board materials and articles intended to come into contact with foodstuffs form a
whole and should be read in conjunction with each other.

Taking the view that each member state, faced with the need to introduce regulations
governing this matter, would find it beneficial to harmonise such regulations at
European level,

Recommends to the governments of the member states of the Partial Agreement in

the Social and Public Health field to take into account in their national laws and
regulations on paper and board materials and articles intended to come into contact
with foodstuffs the principles set out hereafter.

6
 APPENDIX TO RESOLUTION RESAP (2002)1

1. Field of application

This resolution applies to materials and articles constituted of paper and board
(excluding nonwovens 1 ) which may comprise one or more layer(s) of fibres and are
intended to come into contact with or are placed in contact with foodstuffs. A plastic
layer, or a layer of any other material, such as aluminium, waxes or paraffins applied
to the paper and board is excluded from this resolution 2 . When the materials and
articles consist of two or more layers, exclusively or not exclusively made of paper
and board, any layer which is composed of paper and board must fulfil the
requirements of this resolution, unless separated from the foodstuffs by a functional
barrier 3 to migration.

Filtering layers of high grammage 4 and consisting to a large extent of non-fibrous

material as well as tissue paper kitchen towels and napkins are excluded from the
field of application of the present resolution. 5

2. Definition

Paper and board are manufactured from cellulose-based natural fibres from bleached
and unbleached fibre material. Recycled fibre materials may also be used in
accordance with the Guidelines on paper and board materials and articles, made
from recycled fibres, intended to come into contact with foodstuffs, set out in
Technical document No. 3. In addition paper and board may contain functional
additives and synthetic fibres 6 . Paper and board may also contain other treatment
agents and polymeric binders for organic and inorganic pigments.

3. Specifications

3.1. Paper and board used for all food contact applications under normal or
foreseeable conditions of use should meet the following conditions:

3.2. They should not transfer their constituents to foodstuffs in quantities which could
endanger human health or bring about an unacceptable change in the composition of
the foodstuffs or a deterioration in the organoleptic characteristics thereof, in
accordance with Article 2 of Directive 89/109/EEC.

1
As defined by ISO 9092.

2
Examples: Mineral coated papers and their components, including polymeric binders in the coating formula, are subject
to this resolution. The plastic layer, or a layer of any other material, such as aluminium, waxes or paraffins in contact with
foodstuffs, of a coated or laminated paper is excluded from this resolution. The paper behind the layer is not subject to
this resolution if it can be shown that the layer is a functional barrier.
3
A functional barrier is any integral layer which under its normal or foreseeable conditions of use reduces all possible
material transfers (permeation and migration) from any layer beyond the barrier into food to a toxicologically and
organoleptically insignificant and to a technologically unavoidable level.
4
Products with a weight to surface area ratio of 500 g/m2 and above (BgVV Chapter XXXVI/1
Papers and filter beds for use in boiling and hot-filtering).
5
Tissue paper kitchen towels and napkins are covered by specific guidelines.
6
Synthetic fibres should comply with EU Directive 90/128/EEC.

7
3.3. They should be manufactured in accordance with the CEPI guide for good
manufacturing practice for paper and board for food contact set out in Technical
document No. 4 and using the substances of the List of substances used in the
manufacture of paper and board materials and articles intended to come into contact
with foodstuffs set out in Technical document No. 1 and according to the conditions
specified.

3.4. They should be of suitable microbiological quality, taking into account the
intended end use of the material. For materials and articles intended to come into
contact with aqueous and/or fatty foodstuffs, particular attention should be paid to
pathogens.

3.5. They should not release substances which have an antimicrobial effect on
foodstuffs. The method of analysis to be applied is laid down in the Guidelines on
test conditions and methods of analysis for paper and board materials and articles
intended to come into contact with foodstuffs set out in Technical document No 2.

3.6. They should comply with the restrictions laid down in Table 1 and Table 2
hereafter and with either the QM 7 or SML restrictions 8 laid down in the List of
substances used in the manufacture of paper and board materials and articles
intended to come into contact with foodstuffs set out in Technical document No. 1.

Table 1 - Restriction limits (QM) for cadmium, lead and mercury

Substance Restriction
QM limit (mg/dm2 paper and board)

Cadmium 0.002
Lead 0.003
Mercury 0.002
Table 2 - Restriction limit for pentachlorophenol

Substance Purity requirement (mg/kg paper and board)

Pentachlorophenol 0.15
7
The restrictions in Table 1 of this resolution and of the List of substances used in the manufacture of paper and
board materials and articles intended to come into contact with foodstuffs set out in Technical document No. 1,
expressed as QM (maximum permitted quantity of the substance in the finished material or product expressed as mg
per dm2 of the surface in contact with foodstuffs), have been derived from guideline levels laid down in Council of
Europe Resolution AP (96) 4 on maximum and guideline levels and on source-directed measures aimed at reducing
the contamination of food by lead, cadmium and mercury and from the SML (specific migration limit) restrictions as
laid down in EU Directives, respectively, based on toxicological assessment, applying the conventional ratio of 6 dm 2
of material coming into contact with 1 kg of foodstuffs and assuming 100 % migration. For contact conditions where
the mass of food to contact area ratio differs from the conventional ratio of 1 kg to 6 dm 2, the QM restriction to be
applied should be calculated as specified in the Guidelines on test conditions and methods of analysis for paper and
board materials and articles intended to come into contact with foodstuffs set out in Technical document No. 2.
8
The SML restrictions are those set by the Commission of the European Communities in its directives relating to
plastic materials intended to come into contact with foodstuffs.

8
3.7. Verification of compliance with the quantitative restrictions should to be carried
out according to the conditions laid down in the Test conditions and methods of
analysis for paper and board materials and articles intended to come into contact
with foodstuffs set out in Technical document No. 2.

3.8. Testing for compliance with the restrictions in Table 1 is not required for paper
and board materials and articles intended to come into contact with dry foodstuffs or
foodstuffs which are to be shelled, peeled or washed.

3.9. If it can be shown by calculation, taking into account the conditions of

manufacture, that the restrictions laid down in the List of substances used in the
manufacture of paper and board materials and articles intended to come into contact
with foodstuffs set out in Technical document No. 1, cannot be exceeded, no testing
for compliance with these restrictions is necessary.

3.10. Paper and board produced with recycled fibres can be used as food contact
material if it originates from specified qualities of recovered paper and board which
has been subjected to appropriate processing and cleaning, provided that the
finished materials comply with the specifications in this resolution and with the

Guidelines on paper and board materials and articles, made from recycled fibres,
intended to come into contact with foodstuffs set out in Technical document No 3.

3.11. Manufacturers of paper and board for food contact applications should make
sure that they use raw materials produced by processes which reduce dioxins
(polychlorinated dibenzodioxins and dibenzofurans) to levels as low as reasonably
achievable.

9
References:

Council Directive of 21 December 1988 on the approximation of the laws of the

Member States relating to materials and articles intended to come into contact with
foodstuffs (89/109/EEC). Official Journal of the European Communities L40 11.2.89.

Council of Europe Resolution AP (96) 4 on maximum and guideline levels and on

source-directed measures aimed at reducing the contamination of food by lead,
cadmium and mercury. Adopted by the Committee of Ministers on 2 October 1996.

ISO 9092: 1988. Textiles - Nonwovens - Definition.

10
 TECHNICAL DOCUMENT No. 1

LIST OF SUBSTANCES TO BE USED IN THE MANUFACTURE OF

PAPER AND BOARD MATERIALS AND ARTICLES INTENDED TO
COME INTO CONTACT WITH FOODSTUFFS
Version 3 12.02.2009

11
 Table of contents

Page

1. Classification system of substances to be used for materials

and articles intended to come into contact with foodstuffs ................................. 13

2. Introduction ....................................................................................................... 14

3. Information and abbreviations ........................................................................... 15

4. Notes related to the column restrictions and/or specifications .......................... 16

A. List 1 of additives ............................................................................................. . 18

B. Temporary appendix to List 1 of additives ........................................................ . 30

C. List 2 of additives ............................................................................................. . 44

Appendix A .......................................................................................................... . 61

Appendix B .......................................................................................................... . 69

Appendix C .......................................................................................................... . 71

12
1. CLASSIFICATION SYSTEM OF SUBSTANCES TO BE USED FOR MATERIALS AND
ARTICLES INTENDED TO COME INTO CONTACT WITH FOODSTUFFS

General specifications

List 1 - Substances approved for the use of materials and articles intended to come
into contact with food

1. Substances evaluated by SCF, classified in list 0-4, and used in compliance with specific
migration limits or other restrictions, if any;

2. Substances evaluated and approved by the Committee of expert on materials coming into
contact with food;

3. Substances approved in Partial agreement member states or by FDA, based on an

evaluation of a toxicological dossier, which meets the present SCF criteria;

4. Substances authorised as direct food additives in compliance with specific migration limits
or other restrictions;

5. The substances which have been approved by Partial agreement member states or by
FDA applying scientific evaluation criteria of the time of their approval will be listed in a
Temporary Appendix to List 1.

List 2 Substances not approved for the use of materials and articles intended to
come into contact with food

Substances which do not meet the criteria set for List 1 substances.

Complementary specifications

1. The substances of the Temporary Appendix should be integrated in List 1 or List 2 not
later than five years after adoption of the List of substance.

2. List 1 and List 2 will be updated in principle once a year in order to take into account
newly evaluated substances, new submissions by industry or substances to be deleted.

13
2. INTRODUCTION

2.1. The technical document n1 contains the lists of additives which may be used in the
manufacture of paper and board materials and articles intended to come into contact with
foodstuffs.

The lists include:

A. LIST 1 OF ADDITIVES : list of additives assessed

B. TEMPORARY APPENDIX TO LIST 1 OF ADDITIVES : list of additives approved by
Partial Agreement member states or by FDA, applying evaluation criteria at the time
of their approval
C. LIST 2 OF ADDITIVES : list of additives not yet assessed

The monomers used for the manufacture of polymeric additives are included
in 3 appendices:

- Appendix A : monomers assessed.

- Appendix B : monomers approved by Partial Agreement member states

or by FDA, applying evaluation criteria at the time of their approval.

- Appendix C : monomers not yet assessed.

2.2. The following substances are not included even if they are intentionally used and are
authorised:

(a) salts (including double salts and acid salts) of aluminium, ammonium, calcium, iron,
magnesium, potassium and sodium of authorised acids, phenols or alcohols. However,
names containing acid(s), salts appear in the lists, if the corresponding free acid(s)
is (are) not mentioned;

(b) salts (including double salts and acid salts) of zinc of authorised acids, phenols or
alcohols. For these salts a Group SML = 25 mg/kg (expressed as Zn) applies. The same
restriction for Zn applies to:

(i) substances whose name contains acid(s), salts which appear in the lists, if the
corresponding free acid(s) is (are) not mentioned,

(ii) substance 96240.

2.3. The list also does not include the following substances although they may be present:

(a) substances which could be present in the finished product as:

impurities in the substances used,

reaction intermediates,
decomposition products;

(b) oligomers and natural or synthetic macromolecular substances as well as their mixtures,
if the monomers or starting substances required to synthesise them are included in the
lists;

(c) mixtures of the authorised substances.

2.4. Substances shall be of good technical quality as regards the purity criteria

14
3. INFORMATION AND ABBREVIATIONS

The lists contain the following information :

PM/REF No : the EU packaging material reference number of the

substance
CAS No : the Chemical Abstracts Service Registry Number of the
substance
NAME : the chemical name of the substance or the substance
group
SCF-L : the number of the list in which the substance is classified
by the Scientific Committee for food / EFSA
RESTRICTIONS AND/OR : restrictions and/or specifications related to the substance
SPECIFICATIONS
ADI/TDI : acceptable daily intake or tolerable daily intake as
defined in the reports of the Scientific Committee for
food / EFSA.

A number of abbreviations are used under RESTRICTIONS AND/OR SPECIFICATIONS

and ADI/TDI, the meanings of which are as follows :

ACC : acceptable
DL : detection limit of the method of analysis
FCC : Food Chemicals Codex
ND : not detectable
NS : not specified
QM maximum permitted quantity of the residual substance in the material. For the
purpose of this resolution the quantity of the substances in the material shall be
determined by a validated method of analysis. If such a method does not
currently exist, an analytical method with appropriate performance
characteristics at the specified limit may be used, pending the development of a
validated method
QMA : maximum permitted quantity of the residual substance in the material
expressed as mg per 6 dm2 of the surface in contact with foodstuffs. For the
purpose of this resolution the quantity of the substance in the surface of the
material should be determined by a validated method of analysis. If such a
method does not currently exist, an analytical method with appropriate
performance characteristics at the specified limit may be used, pending the
development of a validated method.
SML : specific migration limit in food or in food simulants
SML(T) : specific migration limit in food or in food simulants expressed as total of
moiety/substance(s) indicated

15
4. NOTES RELATED TO THE COLUMN RESTRICTIONS AND/OR SPECIFICATIONS

(1) Warning : there is a risk that the SML could be exceeded in fatty food simulants
(2) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 30015, 30120, 30200, 48030, 48050, 53765, 53860
(3) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 40320, 87040
(4) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as PM/REF N:
15760, 16990, 53650 and 89440
(5) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 48640, 61360, 61600
(6) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 17260, 54880, 59280
(7) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 64300, 85840
(8) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 86960, 87120
(9) Divinylbenzene may contain up to 40 % of ethylvinylbenzene
(10) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 10060, 23920
(11) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 10690, 10780, 10840, 11470, 11590, 11680, 11710, 11830 and
76463
(12) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 19540, 19960, 64800
(13) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 20020, 20110, 20170, 20890, 21010, 21130, 21190
(14) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 12265, 26170, 26320
(15) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 13780, 20590
(16) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 15700, 16600, 16630, 18640, 19110, 25208, 25210, 25240
(17) SML(T) in this specific case means that the restriction shall not be exceeded by
the sum of the migration of the following substances mentioned as
PM/REF N : 93120, 93280
(18) The product should have the following specifications:
Content of mineral hydrocarbons with Carbon number less than 25, not more than
5% (w/w)
Viscosity not less than 11 x 10-6 m2/s (=11 centistokes) at 100C
Average molecular weight not less than 500

16
(19) Polyethyleneglycol (EO<=11) tridecyl ether phosphate (mono-and dialkyl ester)
with a maximum 10% content of polyethyleneglycol (EO<=11) tridecylether
(20) The product should have the following specifications:
- Content of mineral hydrocarbons with Carbon number less than 25, not more
than 5% (w/w)
- Viscosity not less than 8,5 x 10-6 m2/s (=8,5 centistokes) at 100C
- Average molecular weight not less than 480
(21) Minimum viscosity 100 x 10-6 m2/s (=100 centistokes) at 25C
(22) Petroleum hydrocarbon resins, hydrogenated are produced by the catalytic or
thermal polymerisation of dienes and olefins of the aliphatic, alicyclic and/or
monobenzenoid arylalkene types from distillates of cracked petroleum stocks with
a boiling range not greater than 220C, as well as the pure monomers found in
these distillation streams, subsequently followed by distillation, hydrogenation
and additional processing.
Properties
Viscosity: > 3 Pa.s at 120C
Softening point: > 95C as determined by ASTM Method E 28-67
Bromine number: < 40 (ASTM D1159)
The colour of a 50% solution in toluene < 11 on the Gardner scale
Residual aromatic monomer 50 ppm
(23) Polydimethylsiloxane, 3-aminopropyl terminated, polymer with
dicyclohexylmethane-4,4-diisocyanate
The fraction with molecular weight below 1000 should not exceed 1.5% w/w
(24) Polydimethylsiloxane, 3-aminopropyl terminated, polymer with 1-isocyanato-3-
isocyanatomethyl-3,5,5-trimethylcyclohexane
The fraction with molecular weight below 1000 should not exceed 1% w/w
(25) Polyvinyl alcohol
Weight average molecular weight should not be less than 2500 Da
(26) Polyvinylpyrrolidone
The substance shall meet the purity criteria established in Commission Directive
96/77/EC
(27) 95858 Waxes, paraffinic, refined, derived from petroleum based or synthetic
hydrocarbon feedstocks
- Average molecular weight not less than 350
- Viscosity at 100C min 2,5 cSt
- Content of hydrocarbons with carbon number less than 25, not more than
40% w/w

17
 A. LIST 1 OF ADDITIVES

RESTRICTIONS AND/OR ADI/TDI

PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw

(10030) 000514-10-3 Abietic acid 2 1

(10060) 000075-07-0 Acetaldehyde 2 SML(T) = 6 mg/kg (10) 0,1
- 068187-08-6 Acetylated oxidised starch (= E1451) -
30000 000064-19-7 Acetic acid 1 NS
30015 000112-07-2 Acetic acid, 2-butoxyethyl ester 2 SML(T) = 3 mg/kg (2) 0,05
30120 000111-15-9 Acetic acid, 2-ethoxyethyl ester 2 SML(T) = 3 mg/kg (2) 0,05
30200 000110-49-6 Acetic acid, 2-methoxyethyl ester 2 SML(T) = 3 mg/kg (2) 0,05
30295 000067-64-1 Acetone 3
Acids, aliphatic, linear, monocarboxylic, (C2-C24), from natural oils and fats,
18

30610 - and their mono-, di- and triglycerol esters (branched fatty acids at naturally 3
occuring levels are included)
30960 - Acids, aliphatic, monocarboxylic (C6-C22), esters with polyglycerol 1 25
SML(T) = 6 mg/kg (11)
(11470) 000140-88-5 Acrylic acid, ethyl ester 2 0.1 (a.a)
(as acrylic acid)

31542 174254-23-0 Acrylic acid, methyl ester, telomer with 1-dodecanethiol, C16-C18 alkyl 3 QM = 0.5 %
esters
31730 000124-04-9 Adipic acid 1 5
31920 000103-23-1 Adipic acid, bis(2-ethylhexyl) ester 2 SML = 18 mg/kg (1) 0,3
(12310) - Albumin 0
33105 146340-15-0 Alcohols, C12-C14 secondary, beta-(2-hydroxyethoxy), ethoxylated 3 SML = 5 mg/kg
33120 - Alcohols, aliphatic, monohydric, saturated, linear, primary (C4-C24) 3
33350 009005-32-7 Alginic acid 1 NS
33801 - n-Alkyl(C10-C13)benzenesulphonic acid 2 SML = 30 mg/kg 0,5
34230 - Alkyl(C8-C22)sulphonic acid 2 SML = 6 mg/kg 0,1
Alkyl(C8-C22)sulphuric acids, linear, primary, with an even number of
34281 - 3
carbon atoms
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
34560 021645-51-2 Aluminium hydroxide 2 1 (as Al)
34660 001327-41-9 Aluminium hydroxychloride 2 1(as Al)
34720 001344-28-1 Aluminium oxide 2 1 (as Al)
35170 000141-43-5 2-Aminoethanol 3 SML = 0.05 mg/kg
35320 007664-41-7 Ammonia 1 NS
35440 012124-97-9 Ammonium bromide 1 1(as Br)
35600 001336-21-6 Ammonium hydroxide 1 NS
35840 000506-30-9 Arachidic acid 0
36000 000050-81-7 Ascorbic acid 1 ACC
36880 008012-89-3 Beeswax 0
37040 000112-85-6 Behenic acid 0
37280 001302-78-9 Bentonite 3
SML = 0.5 mg/kg. Only to
be used in aqueous
polymer dispersions and
emulsions and at
19

37520 002634-33-5 1,2-Benzisothiazolin-3-one 3 concentrations which do

not result in an anti-
microbial effect at the
surface of the polymer or
on the food itself
37600 000065-85-0 Benzoic acid 1 5
38400 000100-51-6 Benzyl alcohol 1 5
SML(T) = 6 mg/kg (3)
40320 010043-35-3 Boric acid 2 0.1 (as B)
(as B)
40594 000075-65-0 tert-Butanol 3
40720 025013-16-5 tert-Butyl-4-hydroxyanisole (= BHA) 1 SML = 30 mg/kg 0,5
41280 001305-62-0 Calcium hydroxide 1 NS
41520 001305-78-8 Calcium oxide 1 NS
012004-14-7
41600 Calcium sulphoaluminate 2 1 (as Al)
037293-22-4
41760 008006-44-8 Candelilla wax 3
42080 001333-86-4 Carbon black 3 To be fixed
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
42500 - Carbonic acid, salts 1 NS (CO3)
42640 009000-11-7 Carboxymethylcellulose 2 NS
42720 008015-86-9 Carnauba wax 3
42800 009000-71-9 Casein 0
42880 008001-79-4 Castor oil 3
43120 008001-78-3 Castor oil, hydrogenated 3
43280 009004-34-6 Cellulose 0
43600 004080--31-3 1-(3-Chloroallyl)-3,5,7-triaza-1-azoniaadamantane chloride 2 SML = 0.3 mg/kg 0,005
43680 000075-45-6 Chlorodifluoromethane 2 SML = 6 mg/kg 0,1
SML = ND (DL = 0.01
43760 026172-55-4 5-Chloro-3-methyl-4-isothiazolin-3-one 4A
mg/kg)
44160 000077-92-9 Citric acid 1 NS
44640 000077-93-0 Citric acid, triethyl ester 1 20
45450 068610-51-5 p-Cresol - dicyclopentadiene - isobutylene, copolymer 3 SML = 5 mg/kg
45560 014464-46-1 Cristobalite 3
In compliance with the
20

- 009004-53-9 Dextrin -
FCC specifications
46070 010016-20-3 alpha-Dextrin 0
46080 007585-39-9 beta-Dextrin 0
46640 000128-37-0 2,6-Di-tert-butyl-p-cresol (= BHT) 1 SML = 3 mg/kg 0,05
2
46720 004130-42-1 2,6-Di-tert-butyl-4-ethylphenol 3 QMA = 4.8 mg/6 dm

In compliance with the

- 000107-06-2 1,2-Dichloroethane -
FCC specifications
Dicyclopentadiene - indene - styrene - alpha-methylstyrene - vinyltoluene -
47520 - 3 SML = 5 mg/kg
isobutylene, copolymer, hydrogenated
47680 000111-46-6 Diethyleneglycol 2 SML(T) = 30 mg/kg (4) 0,5
48030 000112-34-5 Diethyleneglycol monobutyl ether 2 SML(T) = 3 mg/kg (2) 0,05
48050 000111-90-0 Diethyleneglycol monoethyl ether 2 SML(T) = 3 mg/kg (2) 0,05
(15790) 000111-40-0 Diethylenetriamine 3 SML = 5 mg/kg
48460 000075-37-6 1,1-Difluoroethane 3
48620 000123-31-9 1,4-Dihydroxybenzene 2 SML = 0.6 mg/kg 0,01
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
48640 000131-56-6 2,4-Dihydroxybenzophenone 2 SML(T) = 6 mg/kg (5) 0,1
49225 000124-40-3 Dimethylamine 3 SML = 0.06 mg/kg
49540 000067-68-5 Dimethyl sulphoxide 3
49840 002500-88-1 Dioctadecyl disulphide 2 SML = 3 mg/kg 0,05
025265-71-8
51760 Dipropyleneglycol 2 1,5
000110-98-5
- 055963-33-2 Distarch phosphate (= E1412) - ACC
- 068130-14-3 Distarch phosphate acetate (= E1414) - ACC
(16697) 000693-23-2 Dodecanedioic acid 3
52000 027176-87-0 Dodecylbenzenesulphonic acid 2 SML = 30 mg/kg 0,5
52640 016389-88-1 Dolomite 3
In compliance with the
- - Enzyme preparations - FCC or JECFA
specifications
- 000089-65-6 Erythorbic acid (= E315) - 6
21

52800 000064-17-5 Ethanol 1 ACC

53255 000100-41-4 Ethylbenzene 3 SML = 0.6 mg/kg 0.1 : 10
53280 009004-57-3 Ethylcellulose 2 NS
(16950) 000074-85-1 Ethylene 3
53360 000110-31-6 N,N'-Ethylenebisoleamide 3
53440 005518-18-3 N,N'-Ethylenebispalmitamide 3
53520 000110-30-5 N,N'-Ethylenebisstearamide 3
53540 000107-15-3 Ethylenediamine 2 SML = 12 mg/kg 0,2
53600 000060-00-4 Ethylenediaminetetraacetic acid 2 2,5
53650 000107-21-1 Ethyleneglycol 2 SML(T) = 30 mg/kg (4) 0,5
53670 032509-66-3 Ethyleneglycol bis[3,3-bis(3-tert-butyl-4-hydroxyphenyl)butyrate] 2 SML = 6 mg/kg 0,1
53765 000111-76-2 Ethyleneglycol monobutyl ether 2 SML(T) = 3 mg/kg (2) 0,05
53860 000109-86-4 Ethyleneglycol monomethyl ether 2 SML(T) = 3 mg/kg (2) 0,05
SML = ND (DL = 0.01
(17020) 000075-21-8 Ethylene oxide 4A
mg/kg)
(17050) 000104-76-7 2-Ethyl-1-hexanol 1 SML = 30 mg/kg 0,5
54260 009004-58-4 Ethylhydroxyethylcellulose 2 NS
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
54450 - Fats and oils, from animal or vegetable food sources 3
(17170) 061788-47-4 Fatty acids, coco 3
54710/1 061790-12-3 Fatty acids, tall oil 3
(17236) 061790-37-2 Fatty acids, tallow 3
54760 061790-38-3 Fatty acids, tallow, hydrogenated 3
(17245) 008016-13-5 Fish oil 3
Food starch, modified (with the exception of specific substances mentioned In compliance with the
- - -
elsewhere in the list) FCC specifications
54880 000050-00-0 Formaldehyde 3 SML(T) = 15 mg/kg (6)
55040 000064-18-6 Formic acid 1 3
55120 000110-17-8 Fumaric acid 1 6
- 000526-95-4 Gluconic acid (= E574) - NS
- 000090-80-2 Glucono-delta-lactone (= E 575) -
(17530) 000050-99-7 Glucose 0
In compliance with the
- - Glucose syrup -
FCC specifications
22

- 000142-47-2 Glutamic acid, monosodium salt (= E621) - NS

56080 025637-84-7 Glycerol dioleate 1 NS
56240 027902-24-5 Glycerol diricinoleate 3
56320 001323-83-7 Glycerol distearate 1 NS
Glycerol, esters with acids, aliphatic, saturated, linear, with an even number
56486 - of carbon atoms (C14-C18) and with acids, aliphatic, unsaturated, linear, 3
with an even number of carbon atoms (C16-C18)
56585 - Glycerol, esters with stearic acid ?
56960 025496-72-4 Glycerol monooleate 1 NS
57440 001323-38-2 Glycerol monoricinoleate 3
57520 031566-31-1 Glycerol monostearate 1 NS
- 000056-40-6 Glycine (= E640) - ACC
(18117) 000079-14-1 Glycolic acid 3
58400 009000-30-0 Guar gum 1 NS
58480 009000-01-5 Gum arabic 1 NS
- 010124-56-8 Hexametaphosphoric acid, hexasodium salt - In compliance with the
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
FCC specifications
59240 000124-09-4 Hexamethylenediamine 2 SML = 2.4 mg/kg 0,04
SML(T) = 15 mg/kg (6)
59280 000100-97-0 Hexamethylenetetramine 3
(as formaldehyde)
59760 019569-21-2 Huntite 3
59990 007647-01-0 Hydrochloric acid 1 NS
In compliance with the
- 007722-84-1 Hydrogen peroxide -
FCC specifications
(18880) 000099-96-7 4-Hydroxybenzoic acid 2 10
60160 000120-47-8 4-Hydroxybenzoic acid, ethyl ester 1 10
60200 000099-76-3 4-Hydroxybenzoic acid, methyl ester 1 10
60240 000094-13-3 4-Hydroxybenzoic acid, propyl ester 1 10
60560 009004-62-0 Hydroxyethylcellulose 2 NS
61120 009005-27-0 Hydroxyethyl starch 2 NS
61360 000131-57-7 2-Hydroxy-4-methoxybenzophenone 2 SML(T) = 6 mg/kg (5) 0,1
61600 001843-05-6 2-Hydroxy-4-n-octyloxybenzophenone 2 SML(T) = 6 mg/kg (5) 0,1
23

- 053124-00-8 Hydroxypropyl distarch phosphate (= E1442) - NS

61800 009049-76-7 Hydroxypropyl starch 1 NS
62160 007681-53-0 Hypophosphorous acid, sodium salt 3
62190 008013-17-0 Invert sugar 0
62720 001332-58-7 Kaolin 1 NS
62960 000050-21-5 Lactic acid 1 NS
63240 008006-54-0 Lanolin (Pharmacopeia grade) 0
63280 000143-07-7 Lauric acid 0
63760 008002-43-5 Lecithin 1 NS
63940 008062-15-5 Lignosulphonic acid 3 SML = 0.24 mg/kg
(19534/1) 068424-45-3 Linseed oil fatty acids 3
SML(T) = 0.6 mg/kg (7) 0.01 (as
64300 001310-65-2 Lithium hydroxide 2
(as Li) Li)
- 009000-40-2 Locust bean gum (= E410) - NS
64800 000110-16-7 Maleic acid 2 SML(T) = 30 mg/kg (12) 0,5
64640 001309-42-8 Magnesium hydroxide 1 NS
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
65020 006915-15-7 Malic acid 1 NS
In compliance with the
- 009050-36-6 Maltodextrin -
FCC specifications
65520 000087-78-5 Mannitol 1 ACC
(20020) 000079-41-4 Methacrylic acid 2 SML(T) = 6 mg/kg (13) 0,1
SML(T) = 6 mg/kg (13) 0.1 (as
(21190) 000868-77-9 Methacrylic acid, monoester with ethyleneglycol 2
(as methacrylic acid) m. acid)
65960 000067-56-1 Methanol 3
66240 009004-67-5 Methylcellulose 2 NS
66480 000119-47-1 2,2'-Methylenebis(4-methyl-6-tert-butylphenol) 2 SML = 1.5 mg/kg 0.025
66620 000075-09-2 Methylene chloride 3 SML = 0.05 mg/kg
66700 009004-65-3 Methylhydroxypropylcellulose 2 NS
SML = 0.5 mg/kg. Only to
be used in aqueous
polymer dispersions and
emulsions and at
24

66755 002682-20-4 2-Methyl-4-isothiazolin-3-one 3 concentrations which do

not result in an anti-
microbial effect at the
surface of the polymer or
on the food itself
SML = ND (DL = 0.01
(21940) 000924-42-5 N-Methylolacrylamide 4A
mg/kg)
Residual monomer in
methylsilsesquioxane
66930 068554-70-1 Methylsilsesquioxane 3 < 1 mg
methyltrimethoxysilane/kg
of methylsilsesquioxane
66950 - alpha-Methylstyrene - styrene, copolymer, hydrogenated 3 SML = 5 mg/kg
Montanic acids and/or their esters with ethyleneglycol and/or with 1,3-
67840 - 3
butanediol and/or with glycerol
67850 008002-53-7 Montan wax 3
67891 000544-63-8 Myristic acid 1 NS
68140 007697-37-2 Nitric acid 2 3
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
68320 002082-79-3 Octadecyl 3-(3,5-di-tert-butyl-4-hydroxyphenyl) propionate 2 SML = 6 mg/kg 0.1
69040 000112-80-1 Oleic acid 1 NS
69760 000143-28-2 Oleyl alcohol 3
In compliance with the
- 010028-15-6 Ozone -
FCC specifications
70400 000057-10-3 Palmitic acid 1 NS
(22795/1) - Palm oil fatty acids 3
71680 006683-19-8 Pentaerythritol tetrakis[3-(3,5-di-tert-butyl-4-hydroxyphenyl)propionate] 2 3
In compliance with the
72060 008009-03-8 Petrolatum 9
FCC specifications
72081/10 - Petroleum hydrocarbon resins (hydrogenated) 3 (22)
- - Phosphated distarch phosphate (= E1413) -
72640 007664-38-2 Phosphoric acid 1 70 (as P)
74240 031570-04-4 Phosphorous acid, tris(2,4-di-tert-butylphenyl) ester 2 1
74880 000084-74-2 Phthalic acid, dibutyl ester 2 SML = 3 mg/kg (1) 0,05
25

75120 000084-66-2 Phthalic acid, diethyl ester 2 SML = 12 mg/kg (1) 0,2
(23505) 000110-85-0 Piperazine 3
SML(T) = 6 mg/kg (11) (for
76463 - Polyacrylic acid, salts 3
acrylic acid)
76681 - Polycyclopentadiene, hydrogenated 3 SML = 5 mg/kg (1)
009016-00-6
76721 Polydimethylsiloxane (MW < 6800) 2 (21) 1.5
063148-62-9
Polydimethylsiloxane, 3-aminopropyl terminated, polymer with
76723 167883-16-1 3 (23)
dicyclohexylmethane-4,4-diisocyanate
Polydimethylsiloxane, 3-aminopropyl terminated, polymer with 1-
76725 661476-41-1 3 (24)
isocyanato-3-isocyanatomethyl3-,5,5-trimethyl-cyclohexane
76730 - Polydimethylsiloxane, gamma-hydroxypropylated 2 SML = 6 mg/kg 0.1
76960 025322-68-3 Polyethyleneglycol 2 5
77280 009005-02-1 Polyethyleneglycol dilaurate 2 10
77360 009005-07-6 Polyethyleneglycol dioleate 2 10
77520 061791-12-6 Polyethyleneglycol ester of castor oil 2 SML = 42 mg/kg 0.7
77550 - Polyethyleneglycol ester of coconut oil fatty acids 2 10
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw

77702 - Polyethyleneglycol esters of aliphatic monocarboxylic acids (C6-C22) and 2 10

their ammonium and sodium sulphates
Polyethyleneglycol (EO = 1-50) ethers of linear and branched primary
77708 - 2 SML = 1.8 mg/kg 0.03
alcohols (C8-C22)
77660 - Polyethyleneglycol esters of natural fatty acids 2 10
77895 068439-49-6 Polyethyleneglycol (EO = 2-6) monoalkyl (C16-C18) ether 3 SML = 0.05 mg/kg
Polyethyleneglycol (EO = 1-50) monoalkyl ether (linear and branched, C8-
77897 - 3 SML = 5 mg/kg
C20) sulphate, salts
78080 009004-81-3 Polyethyleneglycol monolaurate 2 10
78160 009004-96-0 Polyethyleneglycol monooleate 2 10
78240 009004-94-8 Polyethyleneglycol monopalmitate 2 10
78320 009004-97-1 Polyethyleneglycol monoricinoleate 2 SML = 42 mg/kg 0,7
79040 009005-64-5 Polyethyleneglycol sorbitan monolaurate 1 10
79120 009005-65-6 Polyethyleneglycol sorbitan monooleate 2 10
79200 009005-66-7 Polyethyleneglycol sorbitan monopalmitate 1 10
79280 009005-67-8 Polyethyleneglycol sorbitan monostearate 1 10
26

79360 009005-70-3 Polyethyleneglycol sorbitan trioleate 2 10

79440 009005-71-4 Polyethyleneglycol sorbitan tristearate 1 10
79520 - Polyethyleneglycol stearate 2 10
79600 009046-01-9 Polyethyleneglycol tridecyl ether phosphate 3 SML = 5 mg/kg (19)
80000 009002-88-4 Polyethylene wax 3
In compliance with the
80077 068441-17-8 Polyethylene, oxidized 7
specifications of E914
- - Polymers of MW > 10,000 made of monomers of appendix A - See appendix A
80640 - Polyoxyalkyl(C2-C4)dimethylpolysiloxane 3
80720 008017-16-1 Polyphosphoric acids 1 70 (as P)
81060 009003-07-0 Polypropylene wax 3
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
Poly-[[6-[N-(2,2,6,6-tetramethyl-4-piperidinyl)-n-butylamino]-
1,3,5-triazine-2,4-diyl][2,2,6,6-tetramethyl-4-piperidinyl)imino]-
1,6-hexanediyl[(2,2,6,6-tetramethyl-4-piperidinyl)imino]]-alpha-
81220 192268-64-7 [N,N,N',N'-tetrabutyl-N"-(2,2,6,6-tetramethyl-4-piperidinyl)-N"- 3 SML = 5 mg/kg
[6-(2,2,6,6-tetramethyl-4-piperidinylamino)-hexyl]-[1,3,5-triazine-
2,4,6-triamine]-omega-N,N,N',N'-tetrabutyl-1,3,5-triazine-2,4-
diamine]
81280 009002-89-5 Polyvinyl alcohol 3 (25)
81500 009003-39-8 Polyvinylpyrrolidone 3 (26)
81600 001310-58-3 Potassium hydroxide 1 NS
0.017 (as
81680 007681-11-0 Potassium iodide 1 SML = 1 mg/kg (as I)
I)
81840 000057-55-6 1,2-Propanediol 1 25
81880 000071-23-8 1-Propanol 3
81882 000067-63-0 2-Propanol 1 1,5
82000 000079-09-4 Propionic acid 1 NS
27

82400 000105-62-4 1,2-Propyleneglycol dioleate 1 25

82960 001330-80-9 1,2-Propyleneglycol monooleate 1 25
83300 001323-39-3 1,2-Propyleneglycol monostearate 1 25
SML = ND (DL = 0.01
(24010) 000075-56-9 Propylene oxide 4A
mg/kg)
83440 002466-09-3 Pyrophosphoric acid 1 70
83470 014808-60-7 Quartz 3
83580/1 008002-13-9 Rapeseed oil 3
(24065/1) - Rapeseed oil fatty acids 3
In compliance with the
- 008016-60-2 Rice bran wax -
FCC specifications
83700 000141-22-0 Ricinoleic acid 3 SML = 42 mg/kg 0.7
83840 008050-09-7 Rosin 2 1
84000 008050-31-5 Rosin, ester with glycerol 1 12,5
84080 008050-26-8 Rosin, ester with pentaerythritol 2 1
84240 065997-13-9 Rosin, hydrogenated, ester with glycerol 3
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
84400 064365-17-9 Rosin, hydrogenated, ester with pentaerythritol 2 1
(24160) 008052-10-6 Rosin tall oil 3
84640 000069-72-7 Salicylic acid 3
84880 000119-36-8 Salicylic acid, methyl ester 1 SML = 30 mg/kg 0,5
85360 000109-43-3 Sebacic acid, dibutyl ester 3
SML(T) = 0.6 mg/kg (7) 0.01 (as
85840 053320-86-8 Silicic acid, lithium magnesium sodium salt 2-3
(as Li) Li)
85980 - Silicic acid, salts 2 NS
86000 - Silicic acid, silylated 3
86240 007631-86-9 Silicon dioxide 1 NS
86285 - Silicon dioxide, silanated 3
86440 Sodium aluminate 2 1 (as Al)
SML(T) = 10 mg/kg (8) 0.7
86480 007631-90-5 Sodium bisulphite 1
(as SO2) (as SO2)
86560 007647-15-6 Sodium bromide 1 1 (as Br)
86720 001310-73-2 Sodium hydroxide 1 NS
28

In compliance with the

- 007681-57-4 Sodium metabisulphite -
specifications of E223
86880 - Sodium mono- or dialkylphenoxybenzenedisulphonate 2 SML = 9 mg/kg 0.15
86920 007632-00-0 Sodium nitrite 3 SML = 0.6 mg/kg
SML(T) = 10 mg/kg (8) 0.7(as
86960 007757-83-7 Sodium sulphite 1
(as SO2) SO2)
SML(T) = 6 mg/kg (3)
87040 001330-43-4 Sodium tetraborate 2 0.1 (as B)
(as B)
SML(T) = 10 mg/kg (8) 0.7(as
87120 007772-98-7 Sodium thiosulphate 1
(as SO2) SO2)
87200 000110-44-1 Sorbic acid 1 25
87280 029116-98-1 Sorbitan dioleate 2 5
87600 001338-39-2 Sorbitan monolaurate 1 5
87680 001338-43-8 Sorbitan monooleate 1 5
87760 026266-57-9 Sorbitan monopalmitate 1 25
87840 001338-41-6 Sorbitan monostearate 1 25
88080 026266-58-0 Sorbitan trioleate 2 5
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
88240 026658-19-5 Sorbitan tristearate 1 25
88320 000050-70-4 Sorbitol 1 ACC
88630/1 008001-22-7 Soybean oil 3
- 009045-28-7 Starch acetate (= E1420) - ACC
- 063798-35-6 Starch acetate adipate (= E1422) - ACC
88800 009005-25-8 Starch, edible 0
88880 068412-29-3 Starch, hydrolysed 0
- 066829-29-6 Starch octenylsuccinate, sodium salt (= E1450) - NS
- 065996-62-5 Starch, oxidised (= E1404) - ACC
- 011120-02-8 Starch phosphate (= E1410) - ACC
89040 000057-11-4 Stearic acid 1 NS
89440 - Stearic acid, esters with ethyleneglycol 2 SML(T) = 30 mg/kg (4) 0.5
- 025383-99-7 Stearoyl-2-lactylic acid, sodium salt (= E481) - 20
91170 000108-30-5 Succinic anhydride 2 NS
91185 000057-50-1 Sucrose 0
In compliance with the
29

- 007446-09-5 Sulphur dioxide -

specifications of E220
91920 007664-93-9 Sulphuric acid 1 NS
92000 007727-43-7 Sulphuric acid, barium salt 3 SML = 1 mg/kg (as Ba)
0.5 (as
92030 010124-44-4 Sulphuric acid, copper salt 2 SML = 30 mg/kg (as Cu)
Cu)
In compliance with the
- 008028-48-6 Sweet orange oil -
FCC specifications
In compliance with the
- 068425-17-2 Syrups, hydrolyzed starch, hydrogenated -
FCC specifications
92080 014807-96-6 Talc 1 NS
(24905) 008002-26-4 Tall oil 3
92100 061789-97-7 Tallow 3
92150 001401-55-4 Tannic acids 3
92160 000087-69-4 Tartaric acid 1 30
In compliance with the
92220 - Terpene resins, natural or synthetic 9
FCC specifications
92350 000112-60-7 Tetraethyleneglycol 1 10
 RESTRICTIONS AND/OR ADI/TDI
PM/REF No CAS No NAME SCF-L
SPECIFICATIONS mg/kg bw
2,2,4,4-Tetramethyl-20-(2,3-epoxypropyl)-7-oxa-3,20-
92700 078301-43-6 diazadispiro[5.1.11.12]- 3 SML = 5 mg/kg
heneicosan-21-one, polymer
92800 000096-69-5 4,4'-Thiobis(6-tert-butyl-3-methylphenol) 2 SML = 0.48 mg/kg 0,008
93120 000123-28-4 Thiodipropionic acid, didodecyl ester 3 SML(T) = 5 mg/kg (17)
93280 000693-36-7 Thiodipropionic acid, dioctadecyl ester 3 SML(T) = 5 mg/kg (17)
93440 013463-67-7 Titanium dioxide 1 ACC
000059-02-9
93520 alpha-Tocopherol 1 ACC
010191-41-0
93540 000108-88-3 Toluene 3 SML = 1.2 mg/kg
(25385) 000102-70-5 Triallylamine 3 To be fixed
94000 000102-71-6 Triethanolamine 3 SML = 0.05 mg/kg
94560 000122-20-3 Triisopropanolamine 3 SML = 5 mg/kg
95200 001709-70-2 1,3,5-Trimethyl-2,4,6-tris(3,5-di-tert-butyl-4-hydroxybenzyl)benzene 2 1
(25910) 024800-44-0 Tripropyleneglycol 2 1,5
(25960) 000057-13-6 Urea 0
30

95680 000121-33-5 Vanillin 1 10

(26320) 002768-02-7 Vinyltrimethoxysilane 3 SML(T) = 0.05 mg/kg (14)
SML = 0.05 mg/kg and
Waxes, paraffinic, refined, derived from petroleum based or synthetic (27). Not to be used for
95858 - 3
hydrocarbon feedstocks paper contacting fatty
foods
Waxes, refined, derived from petroleum based or synthetic hydrocarbon
95859 - 2 (18) 20
feedstocks
In compliance with the
- 093384-22-6 Wheat gluten -
FCC specifications
95870 - Wheat protein 0
In compliance with the
- 091082-88-1 Whey protein -
FCC specifications
White mineral oils, paraffinic, derived from petroleum based hydrocarbon
95883 - 2 (20) 4
feedstocks
95905 013983-17-0 Wollastonite 3
95935 011138-66-2 Xanthan gum 1 NS
96240 001314-13-2 Zinc oxide 2 SML = 25 mg/kg (as Zn) 1(as Zn)
 B. TEMPORARY APPENDIX TO LIST 1 OF ADDITIVES

RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 000071-48-7 Acetic acid, cobalt(II) salt - To be fixed
- 068440-00-6 Acids, fatty (C8-C18), animal - To be fixed
- 068937-84-8 Acids, fatty (C12-C18), methyl esters - To be fixed
- 067701-06-8 Acids, fatty (C14-C18 and C16-C18 unsaturated) - To be fixed
- 085736-49-8 Acids, fatty (C14-C18 and C16-C18 unsaturated), esters with ethyleneglycol - To be fixed
- 097404-28-9 Acids, fatty (C14-C26), aluminium salts - To be fixed
- 067701-03-5 Acids, fatty (C16-C18) - To be fixed
- 067701-08-0 Acids, fatty (C16-C18 and C18 unsaturated) - To be fixed
- 068955-98-6 Acids, fatty (C16-C18 and C18 unsaturated), branched and linear - To be fixed
- 067762-38-3 Acids, fatty (C16-C18 and C18 unsaturated), methyl esters - To be fixed
31352 085116-93-4 Acids, fatty (C16-C18), esters with pentaerythritol 9 To be fixed
31

- 068937-90-6 Acids, fatty (C18 unsaturated), trimers - To be fixed

- 025586-24-7 Acrylamide-acrylic acid-butyl acrylate-styrene, copolymer - To be fixed
- 025037-40-5 Acrylamide-butadiene-styrene, copolymer - To be fixed
- 026590-05-6 Acrylamide-diallyldimethylammonium chloride, copolymer - To be fixed
- 025085-02-3 Acrylamide-sodium acrylate, copolymer - To be fixed
- 035429-19-7 Acrylamide-N,N,N-trimethylaminoethyl methacrylate chloride, copolymer - To be fixed
- 026007-18-1 Acrylic acid-butadiene-fumaric acid-styrene, copolymer - To be fixed
- 009010-77-9 Acrylic acid-ethylene, copolymer - To be fixed
- 025134-51-4 Acrylic acid-2-ethylhexyl acrylate, copolymer - To be fixed
- 085566-12-7 Alcohols, C8-C10 - To be fixed
- - Alcohols, C8-C26 - To be fixed
- 067762-41-8 Alcohols, C10-C16 - To be fixed
- 068526-86-3 Alcohols, C11-C14-iso, C13-rich - To be fixed
- 067989-40-6 Alcohols, C11-C15, secondary - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 068855-56-1 Alcohols, C12-C16 - To be fixed
- 067762-25-8 Alcohols, C12-C18 - To be fixed
- 090604-31-2 Alcohols, C13-C15 - To be fixed
- 067762-30-5 Alcohols, C14-C18 - To be fixed
- 071750-71-5 Alcohols, > C14 - To be fixed
- 067762-27-0 Alcohols, C16-C18 - To be fixed
- 068002-94-8 Alcohols, C16-C18 and C18 unsaturated - To be fixed
- 084539-77-5 Alcohols, C16-C20 - To be fixed
- 090604-32-3 Alcohols, C18-C26 - To be fixed
- 068784-12-3 Alkenyl(C15-C20)succinic anhydride - To be fixed
- 084989-41-3 2-Alkyl(C12-C16)-3-alkylidene(C13-C17)propiolactone - To be fixed
- 098246-87-8 2-Alkyl(C14-C16)-3-alkylidene(C15-C17)propiolactone - To be fixed
(33800) 068411-30-3 Alkyl(C10-C13)benzenesulphonic acid, sodium salts (9) To be fixed
- 085536-14-7 Alkyl(C10-C13 secondary)benzenesulphonic acid - To be fixed
32

- 085117-49-3 Alkyl(C10-C14)benzenesulphonic acid - To be fixed

- 068584-22-5 Alkyl(C10-C18)benzenesulphonic acid - To be fixed
- 063449-41-2 Alkyl(C8-C18)benzyldimethylammonium chlorides - To be fixed
- 068424-85-1 Alkyl(C12-C16)benzyldimethylammonium chlorides - To be fixed
- 085711-69-9 Alkyl(C13-C17 secondary)sulphonic acid, sodium salt - To be fixed
34300 068955-20-4 Alkyl(C16-C18)sulphuric acid, sodium salt 9 To be fixed
- 090640-44-1 N-Alkyl(C12-C22)trimethylenediamines - To be fixed
- 012042-91-0 Aluminium chloride hydroxide - To be fixed
35200 034730-59-1 N-(2-Aminoethyl)-2-aminoethanesulphonic acid, sodium salt 8 To be fixed
(12772) 000140-31-8 N-Aminoethylpiperazine 8 To be fixed
(12775) 000124-68-5 2-Amino-2-methyl-1-propanol 8 To be fixed
- 068441-21-4 Amylodextrin, reaction products with formaldehyde-urea polymer and starch - To be fixed
- 009037-22-3 Amylopectin - To be fixed
- 060164-73-0 Amylopectin acetate - To be fixed
- 113894-91-0 Amylopectin acetate phosphate - To be fixed
- 113894-85-2 Amylopectin, acid-hydrolyzed, octenylsuccinate - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 222021-68-3 Amylopectin, compound with [3-(2,3-dihydroxypropoxy)propyl]silanetriol - To be fixed
Amylopectin 2-[(2,2-dimethoxyethyl)methylamino]-2-oxoethyl 2-hydroxy-3-(tri-
222021-71-8 - To be fixed
- methylammonio)propyl ether, chloride
Amylopectin 2-hydroxy-3-[3-(trihydroxysilyl)propoxy]propyl 2-hydroxy-3-(trimethyl-
222021-66-1 - To be fixed
- ammonio)propyl ether, chloride
- 068936-82-3 Amylopectin 2-hydroxy-3-(trimethylammonio)propyl ether, chloride - To be fixed
Amylopectin 2-hydroxy-3-(trimethylammonio)propyl 2-[methyl(2-oxoethyl)amino]-2-
222021-75-2 - To be fixed
- oxoethyl ether, chloride
- 125109-81-1 Amylopectin octadecenylsuccinate - To be fixed
- 063055-37-8 Amylopectin phosphate - To be fixed
- 143734-26-3 Amylopectin phosphate, 2-(diethylamino)ethyl ether, sodium salt, hydrochloride - To be fixed
- 113894-92-1 Amylopectin phosphate, 2-hydroxypropyl ether - To be fixed
- 009005-82-7 Amylose - To be fixed
- 000084-65-1 Anthraquinone - To be fixed
33

- 000122-18-9 Benzylhexadecyldimethylammonium chloride - To be fixed

- 457883-29-3 4,4'-Bis[(4-amino-6-morpholino-s-triazin-2-yl)amino]-2,2'-stilbenedisulphonic acid, - To be fixed
disodium salt
4,4'-Bis[[4-anilino-6-[bis(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
004404-43-7 - To be fixed
- disulphonic acid
4,4'-Bis[[4-anilino-6-[bis(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
093965-04-9 - To be fixed
- disulphonic acid, ammonium salt, compound with N-(2-aminoethyl)ethanolamine
4,4'-Bis[[4-anilino-6-[bis(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
004193-55-9 - To be fixed
- disulphonic acid, disodium salt
4,4'-Bis[[4-anilino-6-[bis(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
085153-98-6 - To be fixed
- disulphonic acid, potassium salt, compound with 2-aminoethanol
4,4'-Bis[[4-anilino-6-[bis(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
070942-01-7 - To be fixed
- disulphonic acid, potassium sodium salt
- 027344-06-5 4,4'-Bis[[4-anilino-6-[(2-carbamoylethyl)-(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]- - To be fixed
2,2'-stilbenedisulphonic acid, disodium salt
- 003426-43-5 4,4'-Bis[(4-anilino-6-methoxy-s-triazin-2-yl)amino]-2,2'-stilbenedisulphonic acid, - To be fixed
disodium salt
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
4,4'-Bis[(4-anilino-6-morpholino-s-triazin-2-yl)amino]-2,2'-stilbenedisulphonic acid,
016090-02-1 - To be fixed
- disodium salt
4,4'-Bis[[4-[bis(2-hydroxyethyl)amino]-6-(2,5-disulphoanilino)-s-triazin-2-yl]amino]-
068971-49-3 - To be fixed
- 2,2'-stilbenedisulphonic acid, hexasodium salt
4,4'-Bis[[4-[bis(2-hydroxyethyl)amino-6-methoxy]-s-triazin-2-yl]amino]-2,2'-stilbene-
085187-63-9 disulphonic acid, sodium salt, compound with 2-aminoethanesulphonic acid, - To be fixed
- monosodium salt and diethanolamine
4,4'-Bis[[4-[bis(2-hydroxyethyl)amino-6-methoxy]-s-triazin-2-yl]amino]-2,2'-stilbene-
085187-64-0 - To be fixed
- disulphonic acid, sodium salt, compound with diethanolamine
4,4'-Bis[[4-[bis(2-hydroxyethyl)amino]-6-(p-sulphoanilino)-s-triazin-2-yl]amino]-2,2'-
093965-02-7 - To be fixed
- stilbenedisulphonic acid, sodium salt, compound with diethanolamine
4,4'-Bis[[4-[bis(2-hydroxyethyl)amino]-6-(p-sulphoanilino)-s-triazin-2-yl]amino]-2,2'-
016470-24-9 - To be fixed
- stilbenedisulphonic acid, tetrasodium salt
- 003654-77-1 4,4'-Bis[[4,6-bis[(2-hydroxyethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbenedisulphonic - To be fixed
acid, disodium salt
34

4,4'-Bis[[4-[bis(2-hydroxypropyl)amino]-6-(p-sulphoanilino)-s-triazin-2-yl]amino]-2,2'-
067786-25-8 - To be fixed
- stilbenedisulphonic acid, tetrasodium salt
- 142050-95-1 4,4'-Bis[[4-chloro-6-(2,5-disulphoanilino)-s-triazin-2-yl]amino]-2,2'-stilbenedisulphonic - To be fixed
acid, hexasodium salt
- 031075-24-8 Bis(2-chloroethyl) ether - N,N,N',N'-tetramethylethylenediamine, copolymer - To be fixed
- 037138-26-4 4,4'-Bis[[4-chloro-6-(4-sulphoanilino)-s-triazin-2-yl]amino]-2,2'-stilbenedisulphonic - To be fixed
acid, tetrasodium salt
- 061789-77-3 Bis(coco alkyl)dimethylammonium chloride - To be fixed
- 076508-02-6 4,4'-Bis[[4-[(2-cyanoethyl) (2-hydroxypropyl)amino]-6-(2,5-disulphoanilino)-s-triazin-2- - To be fixed
yl]amino]-2,2'-stilbenedisulphonic acid, hexasodium salt
4,4'-Bis[[4-diethylamino-6-(2,5-disulphoanilino)-s-triazin-2-yl]amino]-2,2'-stilbene-
041098-56-0 (7) To be fixed
(38870) disulphonic acid, hexasodium salt
- 030381-98-7 Bis[2-[N-ethyl(perfluorooctane)sulphonamido]ethyl] phosphate, ammonium salt - To be fixed
4-[[4-[Bis(2-hydroxyethyl)amino]-6-methoxy-s-triazin-2-yl]amino]-4'-[[4-methoxy-
085154-06-9 6-[(2-sulphoethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbenedisulphonic acid, sodium - To be fixed
- salt, compound with diethanolamine
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
4-[[4-[Bis(2-hydroxyethyl)amino]-6-methoxy-s-triazin-2-yl]amino]-4'-[[4-methoxy-
6-[(2-sulphoethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbenedisulphonic acid, sodium
085305-32-4 - To be fixed
salt, compounds with 2-aminoethanesulphonic acid, monosodium salt and
- diethanolamine
- 061791-31-9 N,N-Bis(2-hydroxyethyl)cocoalkylamine - To be fixed
39280 000120-40-1 N,N-Bis(2-hydroxyethyl)lauramide 7 To be fixed
39520 000093-82-3 N,N-Bis(2-hydroxyethyl)stearamide 7 To be fixed
- 001854-26-8 N,N'-Bis(hydroxymethyl)-4,5-dihydroxyethyleneurea - To be fixed
4,4'-Bis[[4-methoxy-6-[(2-sulphoethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
085169-39-7 disulphonic acid, sodium salt, compound with 2-aminoethanesulphonic acid, - To be fixed
- monosodium salt and diethanolamine
4,4'-Bis[[4-methoxy-6-[(2-sulphoethyl)amino]-s-triazin-2-yl]amino]-2,2'-stilbene-
085154-07-0 - To be fixed
- disulphonic acid, sodium salt, compound with diethanolamine
4,4'-Bis[[4-morpholino-6-(2,5-disulphoanilino)-s-triazin--2-yl]amino]-2,2'-stilbene-
052301-70-9 (7) To be fixed
(39945) disulphonic acid, hexasodium salt
35

4,4'-Bis[[4-morpholino-6-(2,5-disulphoanilino)-s-triazin--2-yl]amino]-2,2'-stilbene-
093940-63-7 (7) To be fixed
(39945) disulphonic acid, sodium salt
- 016079-88-2 1-Bromo-3-chloro-5,5-dimethylhydantoin - To be fixed
- 002491-38-5 2-Bromo-4'-hydroxyacetophenone - To be fixed
- 001303-86-2 Boron oxide - To be fixed
40460 000052-51-7 2-Bromo-2-nitro-1,3-propanediol 8 To be fixed
40480 007166-19-0 2-Bromo-2-nitrostyrene 8 To be fixed
40592 000078-92-2 2-Butanol 8 To be fixed
- 013397-26-7 Calcite - To be fixed
- 023570-56-1 Carbonic acid, potassium zirconium salt - To be fixed
- 059419-62-4 Carboxymethyl starch-epichlorohydrin, copolymer - To be fixed
- 068459-67-6 Castor oil, ester with glycerol - To be fixed
43230 008002-33-3 Castor oil, sulphated 9 To be fixed
- 068187-76-8 Castor oil, sulphated, sodium salt - To be fixed
- 009012-54-8 Cellulase - To be fixed
- 010049-04-4 Chlorine dioxide - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 000079-07-2 Chloroacetamide - To be fixed
- 051229-78-8 cis-1-(3-Chloroallyl)-3,5,7-triaza-1-azoniaadamantane chloride - To be fixed
43630 000059-50-7 p-Chloro-m-cresol 8 To be fixed
- 060736-58-5 2-Chloro-3-(phenylsulphonyl)acrylonitrile - To be fixed
- 007758-19-2 Chlorous acid, sodium salt - To be fixed
43840 015659-56-0 Chromic chloride myristate 8 To be fixed
- 061788-46-3 Cocoalkylamines - To be fixed
- 061789-18-2 Cocoalkyltrimethylammonium chloride - To be fixed
- 000138-93-2 Cyanothiocarbamic acid, disodium salt - To be fixed
45700 000110-82-7 Cyclohexane 8 To be fixed
45710 000108-93-0 Cyclohexanol 8 To be fixed
- 076386-11-3 1-Decenylsuccinic acid - To be fixed
- 039306-95-1 Dextrin 2-hydroxypropyl ether - To be fixed
- 065546-83-0 Dextrin 2-hydroxy-3-(trimethylammonio)propyl ether, chloride - To be fixed
36

- 039405-17-9 Dextrin phosphate - To be fixed

- 068424-95-3 Dialkyl(C8-C10)dimethylammonium chlorides - To be fixed
- 068391-05-9 Dialkyl(C12-C18)dimethylammonium chlorides - To be fixed
- 010222-01-2 2,2-Dibromo-2-cyanoacetamide - To be fixed
- 035691-65-7 1,2-Dibromo-2,4-dicyanobutane - To be fixed
- 009067-34-9 Dicarboxy starch - To be fixed
- 001192-52-5 4,5-Dichloro-1,2-dithiol-3-one - To be fixed
- 000107-06-2 1,2-Dichloroethane - To be fixed
- 061789-77-3 Dicocoalkyldimethylammonium chloride - To be fixed
- 007173-51-5 Didecyldimethylammonium chloride - To be fixed
47620 000111-42-2 Diethanolamine W8 To be fixed
2-(Diethylamino)ethyl methacrylate 2,3-epoxypropyl methacrylate
- To be fixed
- - perfluoroalkyl(C4-C18)ethyl acrylate
2-(Dimethylamino)ethyl methacrylate perfluoroalkylethyl acrylate vinyl acetate,
- To be fixed
- - copolymer
47720 000120-55-8 Diethyleneglycol dibenzoate W To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
48340 000140-01-2 Diethylenetriaminepentaacetic acid, pentasodium salt 8 To be fixed
- 015827-60-8 Diethylenetriaminepenta(methylenephosphonic acid) - To be fixed
- 068155-78-2 Diethylenetriaminepenta(methylenephosphonic acid), heptasodium salt - To be fixed
- 022042-96-2 Diethylenetriaminepenta(methylenephosphonic acid), sodium salt - To be fixed
- 085409-22-9 Dimethylalkyl(C12-C14)benzylammonium chloride - To be fixed
49202 068391-01-5 Dimethylalkyl(C12-C18)benzylammonium chloride 9 To be fixed
- 068609-88-1 Dimethylamine-epichlorohydrin, copolymer - To be fixed
- 042751-79-1 Dimethylamine-ethylenediamine-epichlorohydrin, copolymer - To be fixed
(16180) 005205-93-6 N-(Dimethylaminopropyl)methacrylamide 6A To be fixed
49340 061789-71-7 Dimethyl(coco alkyl)benzylammonium chloride 9 To be fixed
- 005538-94-3 Dimethyldioctylammonium chloride - To be fixed
- 000128-04-1 Dimethyldithiocarbamic acid, sodium salt - To be fixed
49560 000533-74-4 3,5-Dimethyl-1,3,5,2H-tetrahydrothiadiazine-2-thione 8 To be fixed
51840 027138-31-4 Dipropyleneglycol dibenzoate 7 To be fixed
37

- - Distarch phosphate, carboxymethyl ether - To be fixed

- 064742-47-8 Distillates (petroleum), hydrotreated light - To be fixed
- 058598-42-8 Docosenylsuccinic anhydride - To be fixed
- 029658-97-7 Dodecenylsuccinic acid - To be fixed
- 013877-83-3 2-Dodecenylsuccinic acid - To be fixed
- 013590-97-1 Dodecylguanidine hydrochloride - To be fixed
- 000112-55-0 n-Dodecyl mercaptan - To be fixed
- 025103-58-6 tert-Dodecyl mercaptan - To be fixed
- 083708-14-9 2-Eicosyl-3-heneicosylidenepropiolactone - To be fixed
- 058944-89-1 Epichlorohydrin-starch, copolymer - To be fixed
- 068412-87-3 Epichlorohydrin-starch hydroxypropyl ether, copolymer - To be fixed
Epichlorohydrin starch, 2-hydroxy-3-(trimethylammonio)propyl ether, chloride,
- 164332-87-6 - To be fixed
copolymer
- 003586-55-8 Ethyleneglycol bis(hydroxymethyl ether) - To be fixed
(54120) 000136-53-8 2-Ethylhexanoic acid, zinc salt - To be fixed
- 000126-92-1 2-Ethylhexylsulphuric acid, sodium salt - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
N-Ethyl-N-(2-hydroxyethyl)perfluorooctanesulphonamide phosphate, diammonium
067969-69-1 - To be fixed
- salt
- 213910-67-9 N,N'-Ethylidenebis[(3-sulpho-4,1-phenylene)imino(6-[(2,5-disulphophenyl)amino]- - To be fixed
1,3,5-triazine-4,2-diyl]]bis-aspartic acid, decasodium salt
- 174305-36-3 N,N'-Ethylidenebis[(3-sulpho-4,1-phenylene)imino(6-[(4-sulphophenyl)amino]- - To be fixed
1,3,5-triazine-4,2-diyl]]bis[N-(carboxymethyl)glycine], octasodium salt
- - Fatty acids, esters with mono- and polyhydric alcohols (C1-C18) - To be fixed
- 067762-63-4 Fatty acids, tall oil, butyl esters - To be fixed
- 061788-61-2 Fatty acids, tallow, methyl esters - To be fixed
- 068938-25-0 Fish oil fatty acids, hydrogenated - To be fixed
(54900) 093924-63-1 Formaldehyde-naphthalenesulphonic acid, copolymer, ammonium salts - To be fixed
(54900) 091078-68-1 Formaldehyde-naphthalenesulphonic acid, copolymer, sodium salts - To be fixed
- 037281-53-1 Formaldehyde-starch-urea, copolymer - To be fixed
55030 009011-05-6 Formaldehyde-urea, copolymer D To be fixed
38

- 031138-65-5 Glucoheptonic acid, sodium salt - To be fixed

- 000087-74-1 Glucoheptonic acid - To be fixed
55660 000111-30-8 Glutaraldehyde 7 To be fixed
- 000122-32-7 Glycerol trioleate - To be fixed
58310 000107-22-2 Glyoxal 6A To be fixed
- 039346-76-4 Guar gum, carboxymethyl ether, sodium salt - To be fixed
- 039421-75-5 Guar gum, 2-hydroxypropyl ether - To be fixed
- 056000-16-9 3-(8-Heptadecenylidene)-2-(7-hexadecenyl)propiolactone - To be fixed
- 010126-68-8 3-Heptadecylidene-2-hexadecylpropiolactone - To be fixed
- 032072-96-1 Hexadecenylsuccinic anhydride - To be fixed
- 000112-02-7 Hexadecyltrimethylammonium chloride - To be fixed
59600 000107-41-5 Hexyleneglycol 7 To be fixed
- 267233-58-9 Hydrocarbons, resins, aliphatic - To be fixed
- 267233-95-4 Hydrocarbons, resins, aromatic - To be fixed
- 267233-74-9 Hydrocarbons, resins, hydrogenated - To be fixed
- 000139-89-9 N-(2-Hydroxyethyl)ethylenediaminetriacetic acid, trisodium salt - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
61340 000149-44-0 Hydroxymethanesulphinic acid, sodium salt 8 To be fixed
- 051026-28-9 N-Hydroxymethyl-N-methyldithiocarbamic acid, potassium salt - To be fixed
62110 007681-52-9 Hypochlorous acid, sodium salt 6A To be fixed
- 072749-55-4 Imidazolium compounds, 2-(C17 and C17-unsaturated alkyl)-1-[2-(C18 and C18- - To be fixed
unsaturated amino)ethyl]-4,5-dihydro-1-methyl, methyl sulphates
62270 000078-83-1 Isobutanol 8 To be fixed
- 058239-72-8 Isooctadecenylsuccinic anhydride - To be fixed
- 001318-74-7 Kaolinite - To be fixed
62860 008008-20-6 Kerosene 9 To be fixed
- 068424-48-6 Marine-oil fatty acids, hydrogenated - To be fixed
65768 000149-30-4 2-Mercaptobenzothiazole 6A To be fixed
65770 002492-26-4 2-Mercaptobenzothiazole, sodium salt 6A To be fixed
- 013701-59-2 Metaboric acid, barium salt - To be fixed
Methacrylic acid, 2-(dimethylamino)ethyl ester, polymers with gamma-omega-per-
39

- 479029-28-2 - To be fixed
fluoro-C8-14-alkyl acrylate, acetates, N-oxides
- 783306-31-0 Methacrylic acid, 2-(dimethylamino)ethyl ester, polymers with gamma-omega-per- - To be fixed
fluoro-C8-14-alkyl acrylate, N-oxides
- 000137-41-7 Methyldithiocarbamic acid, potassium salt - To be fixed
- 006317-18-6 Methylenebis(thiocyanate) - To be fixed
- 160808-63-9 3-(15-Methylhexadecylidene)-2-(14-methylpentadecyl)propiolactone - To be fixed
- 000137-20-2 N-Methyl-N-oleoyltaurine - To be fixed
66905 000872-50-4 N-Methylpyrrolidone 8 To be fixed
- 012001-26-2 Mica-group minerals - To be fixed
- 085117-50-6 Monoalkyl(C10-C14)benzenesulphonic acid, sodium salts - To be fixed
- 001318-93-0 Montmorillonite - To be fixed
- 000110-27-0 Myristic acid, isopropyl ester - To be fixed
- 064741-65-7 Naphtha (petroleum), heavy alkylate - To be fixed
- 064742-48-9 Naphtha (petroleum), hydrotreated heavy - To be fixed
- 028777-98-2 Octadecenylsuccinic anhydride - To be fixed
- 014481-60-8 N-Octadecyl-2-sulphosuccinamic acid, disodium salt - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
69480 000112-62-9 Oleic acid, methyl ester 7 To be fixed
69560 003687-45-4 Oleic acid, oleyl ester 7 To be fixed
- 068188-18-1 Paraffin oils, sulphochlorinated, saponified - To be fixed
- 000079-21-0 Peroxyacetic acid - To be fixed
72046 007727-54-0 Persulphuric acid, ammonium salt 8 To be fixed
72048 007727-21-1 Persulphuric acid, potassium salt 8 To be fixed
72240 000090-43-7 2-Phenylphenol D To be fixed
- 013707-65-8 2-Phenylphenol, potassium salt - To be fixed
- 000132-27-4 2-Phenylphenol, sodium salt - To be fixed
- 010154-75-3 3-(Phenylsulphonyl)propionitrile - To be fixed
Phosphoric acid, mono- and bis(gamma, omega-perfluoroalkyl) esters, compounds
- To be fixed
- - with diethanolamine
73680 000126-73-8 Phosphoric acid, tributyl ester 6B To be fixed
73840 000126-71-6 Phosphoric acid, triisobutyl ester 6B To be fixed
40

76430 008002-09-3 Pine oil 8 To be fixed

- - Plastic dispersions in compliance with recommendation XIV of BfR - To be fixed
- 026062-79-3 Poly(diallyldimethylammonium chloride) - To be fixed
- 068989-57-1 Polyethyleneglycol diesters of fatty acids (C16-C18 and C18 unsaturated) - To be fixed
- 061791-01-3 Polyethyleneglycol diesters of tall oil fatty acids - To be fixed
- 009014-92-0 Polyethyleneglycol dodecylphenyl ether - To be fixed
- 068131-40-8 Polyethyleneglycol ethers of C11-C15-secondary alcohols - To be fixed
- 084133-50-6 Polyethyleneglycol ethers of C12-C14 secondary alcohols - To be fixed
- 031694-55-0 Polyethyleneglycol glyceryl triether - To be fixed
- 009004-74-4 Polyethyleneglycol monomethyl ether - To be fixed
78400 009016-45-9 Polyethyleneglycol nonylphenyl ether P To be fixed
- 068412-54-4 Polyethyleneglycol nonylphenyl ether, branched - To be fixed
78440 026027-38-3 Polyethyleneglycol 4-nonylphenyl ether W7 To be fixed
- 009051-57-4 Polyethyleneglycol nonylphenyl ether ammonium sulphate - To be fixed
- 009036-19-5 Polyethyleneglycol tert-octylphenyl ether - To be fixed
- 009002-93-1 Polyethyleneglycol 4-tert-octylphenyl ether - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 026636-37-3 Polyethyleneglycol 2,4,6-tri-tert-butylphenyl ether - To be fixed
- 060828-78-6 Polyethyleneglycol 2,6,8-trimethyl-4-nonyl ether - To be fixed
- - Polymers of MW > 10,000 made of monomers of appendices A and B - To be fixed
80650 - Polypropyleneglycol butyl ether 9 To be fixed
- - Polypropyleneglycol esters of fatty acids - To be fixed
81245 009003-20-7 Polyvinyl acetate D To be fixed
- - Potato protein - To be fixed
- 068153-38-8 Resin acids and rosin acids, esters with diethyleneglycol - To be fixed
- 008050-25-7 Resin acids and rosin acids, esters with triethyleneglycol - To be fixed
- 084776-83-0 Resin acids and rosin acids, esters with trimethylolpropane - To be fixed
- 008050-33-7 Resin acids and rosin acids, ethoxylated - To be fixed
- 094581-17-6 Resin acids and rosin acids, maleated, esters with pentaerythritol - To be fixed
- 068201-60-5 Resin acids and rosin acids, maleated, sodium salts - To be fixed
- 094114-24-6 Resin acids and rosin acids, tall-oil, maleated, reaction products with formaldehyde - To be fixed
- 000141-24-2 Ricinoleic acid, methyl ester - To be fixed
41

- 065997-04-8 Rosin, fumarated - To be fixed

- 095009-65-7 Rosin, fumarated, reaction products with formaldehyde - To be fixed
- 008050-28-0 Rosin, maleated - To be fixed
- 091081-53-7 Rosin, reaction products with formaldehyde - To be fixed
- - Silicones in compliance with Recommendation XV of the BfR - To be fixed
86670 007775-14-6 Sodium dithionite 8 To be fixed
- 001313-60-6 Sodium peroxide - To be fixed
- 064742-95-6 Solvent naphtha (petroleum), light aromatic - To be fixed
- 104037-82-3 Starch acetate, acid-hydrolyzed - To be fixed
- 114471-59-9 Starch, acetate, 2-hydroxy-3-(trimethylammonio)propyl ether, chloride - To be fixed
- 009067-33-8 Starch acetate phosphate - To be fixed
- 068511-18-2 Starch borate - To be fixed
- 089592-31-4 Starch carbamate - To be fixed
- 063100-00-5 Starch carbamate dihydrogen phosphate - To be fixed
- - Starch carbamate, hydrolyzed - To be fixed
- 009057-06-1 Starch carboxymethyl ether - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 009063-38-1 Starch carboxymethyl ether, sodium salt - To be fixed
- 009063-39-2 Starch 2-cyanoethyl ether - To be fixed
- 009047-50-1 Starch 2,3-dialdehyde - To be fixed
Starch 2-(diethylamino)ethyl 2-[(2,2-dimethoxyethyl)methylamino]-2-oxoethyl
- 102962-62-9 - To be fixed
ether, hydrochloride
- 037265-07-9 Starch 2-(diethylamino)ethyl ether, hydrochloride - To be fixed
- 068650-82-8 Starch 2-(diethylamino)ethyl ether, hydrochloride, oxidized - To be fixed
- - Starch diglycerol, acetylated - To be fixed
Starch, dihydrogen phosphate, 2-hydroxy-3-(trimethylammonio)propyl ether,
- 070563-14-3 - To be fixed
chloride
- 222021-87-6 Starch, dihydrogen phosphate, 2-hydroxy-3-(trimethylammonio)propyl ether, - To be fixed
chloride, sodium salt
- 068584-87-2 Starch 2-hydroxyethyl ether, oxidized - To be fixed
- 068412-86-2 Starch 2-hydroxypropyl ether, oxidized - To be fixed
- 222021-85-4 Starch 2-hydroxypropyl 2-hydroxy-3-(trimethylammonio)propyl ether, chloride - To be fixed
42

- 056780-58-6 Starch 2-hydroxy-3-(trimethylammonio)propyl ether, chloride - To be fixed

- 224319-61-3 Starch 2-hydroxy-3-(trimethylammonio)propyl ether, chloride, hydrolyzed - To be fixed
- 221897-48-9 Starch 2-hydroxy-3-(trimethylammonio)propyl ether, chloride, oxidized - To be fixed
- 070563-14-3 Starch 2-hydroxy-3-(trimethylammonio)propyl ether, chloride, phosphate - To be fixed
Starch 2-hydroxy-3-(trimethylammonio)propyl ether, chloride, sodium octenyl-
- - - To be fixed
succinate
- 039433-66-4 Starch maleate - To be fixed
- 009087-61-0 Starch octenylsuccinate, aluminium salt - To be fixed
- 143734-28-5 Starch phosphate, 2-(diethylamino)ethyl ether, sodium salt, hydrochloride - To be fixed
- 068921-22-2 Starch, reaction products with dimethylolethyleneurea - To be fixed
- 068584-90-7 Starch, reaction products with formaldehyde - To be fixed
- 039316-70-6 Starch succinate - To be fixed
- 011097-99-7 Starch sulphate - To be fixed
91630 003006-15-3 Sulphosuccinic acid, dihexyl ester, sodium salt 6B To be fixed
91680 001639-66-3 Sulphosuccinic acid, dioctyl ester, sodium salt 6B To be fixed
91760 002673-22-5 Sulphosuccinic acid, ditridecyl ester, sodium salt 6B To be fixed
- 085631-69-2 Tall-oil rosin, fumarated - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 095009-66-8 Tall-oil rosin, fumarated, reaction products with formaldehyde - To be fixed
- 008030-12-4 Tallow, hydrogenated - To be fixed
- 055566-30-8 Tetrakis(hydroxymethyl)phosphonium sulphate - To be fixed
92720 000137-26-8 N,N'-Tetramethylthiuram disulphide 8 To be fixed
- 021564-17-0 2-(Thiocyanomethylthio)benzothiazole - To be fixed
93585 000104-15-4 p-Toluenesulphonic acid 8 To be fixed
(25520) 000112-24-3 Triethylenetetramine 8 To be fixed
(25970) 061788-66-7 Vegetable oil fatty acids 9 To be fixed
- - Vegetable oil fatty acids, hydrogenated - To be fixed
- 130498-22-5 Wheat flour - To be fixed
- 009025-57-4 Xylanase - To be fixed
- 001300-72-7 Xylenesulphonic acid, sodium salt - To be fixed
- 001318-02-1 Zeolites - To be fixed
032535-84-5
43

96480 Zirconyl ammonium carbonate 7 To be fixed

068309-95-5
 C. LIST 2 OF ADDITIVES

RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 000125-12-2 Acetic acid, isobornyl ester - To be fixed
- 007585-20-8 Acetic acid, zirconium salt - To be fixed
- 090990-25-3 Acids, fatty (C8-C18 and C18 unsat.), alkyl(C16-C22) esters - To be fixed
31306 092797-30-3 Acids, fatty (C14-C22), alkyl(C16-C24) esters 9 To be fixed
32240 000105-99-7 Adipic acid, dibutyl ester 6B To be fixed
32760 000627-93-0 Adipic acid, dimethyl ester 6B To be fixed
- 090622-25-6 Alcohols, C8-C22, distillation residues - To be fixed
- 068603-18-9 Alcohols, C10-C16, distillation residues - To be fixed
- 068603-17-8 Alcohols, C16-C18, distillation residues - To be fixed
- 068911-61-5 Alcohols, C18-C32 - To be fixed
- 098072-31-2 Alkenes (C7-C9), hydroformylation products, distillation residues, heavy cracked - To be fixed
44

- 068955-53-3 tert-Alkyl(C12-C14)amines - To be fixed

- 073138-27-9 tert-Alkyl(C12-C14)amines, ethoxylated - To be fixed
- 070592-80-2 Alkyl(C10-C16)dimethylamines N-oxides - To be fixed
- 084501-33-7 Alkyl(C12-C16, branched and linear)dimethylbetaines - To be fixed
- 068391-11-7 Alkylpyridine - To be fixed
- 085665-45-8 Alkyl(C8-C14)sulphuric acid, compounds with triethanolamine - To be fixed
- 090640-46-3 N-Alkyl(C12-C18)trimethylenediamines diacetates - To be fixed
- 068439-73-6 N-Alkyl(C14-C18 and C16-C18 unsaturated)trimethylenediamines - To be fixed
(12610) 000107-18-6 Allyl alcohol 6A To be fixed
- 039290-78-3 Aluminium chloride hydroxide sulphate - To be fixed
- 000300-92-5 Aluminium hydroxide distearate - To be fixed
- 131148-05-5 Aluminium hydroxide silicate sulphate - To be fixed
- 001332-73-6 Aluminium hydroxide sulphate - To be fixed
(12730) 000060-32-2 6-Aminocaproic acid 8 To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 006281-42-1 N-(2-Aminoethyl)ethyleneurea - To be fixed
- 000093-81-2 N-(2-Aminoethyl)-N-(2-hydroxyethyl)oleamide - To be fixed
- 001758-73-2 Aminoiminomethanesulphinic acid - To be fixed
- 000078-96-6 1-Amino-2-propanol - To be fixed
- 007617-78-9 3-Aminopropyl decyl ether - To be fixed
- 000105-83-9 N-(3-Aminopropyl)-N-methyl-1,3-propanediamine - To be fixed
- 068511-40-0 3-Aminopropyl tridecyl ether, branched - To be fixed
35300 000919-30-2 3-Aminopropyltriethoxysilane 8 To be fixed
- 013822-56-5 3-Aminopropyltrimethoxysilane - To be fixed
- 002869-34-3 1-Aminotridecane - To be fixed
- 065545-83-7 Ammonium chloride-dicyandiamide-ethylenediamine-formaldehyde, copolymer - To be fixed
- 027776-21-2 Azobis(2-imidazolinylpropane) dihydrochloride - To be fixed
- 013472-08-7 Azobis(2-methylbutyronitrile) - To be fixed
38280 000106-51-4 Benzoquinone 8 To be fixed
45

- 000095-14-7 1H-Benzotriazole - To be fixed

- 094891-33-5 Benzyldimethyloctadecylammonium chloride, reaction products with hectorite - To be fixed
- 000111-44-4 Bis(2-chloroethyl) ether - To be fixed
Bis(2-hydroxy-3-chloropropyl)methylamine - N,N,N',N'-tetramethylethylenediamine,
- 068140-76-1 - To be fixed
copolymer
- 000139-41-3 N,N-Bis(2-hydroxyethyl)aminoacetic acid, sodium salt - To be fixed
39480 000093-83-4 N,N-Bis(2-hydroxyethyl)oleamide 7 To be fixed
- 061791-44-4 N,N-Bis(2-hydroxyethyl)tallowalkylamine - To be fixed
39630 000140-95-4 N,N'-Bis(hydroxymethyl)urea 8 To be fixed
- 004767-03-7 2,2-Bis(hydroxymethyl)propionic acid - To be fixed
- 035674-65-8 1,3-Bis(3-octadecylureido)propane - To be fixed
- 027344-41-8 4,4'-Bis(2-sulphostyryl)biphenyl, disodium salt - To be fixed
- 090268-92-1 Bis(tallow alkyl)carbamoyl chloride - To be fixed
- 035950-52-8 2-(2-Bromo-2-nitrovinyl)furan - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 067953-19-9 2-Butenedioic acid, bis(1,3-dimethylbutyl) ester - To be fixed
40618 005131-66-8 1-Butoxy-2-propanol 8 To be fixed
- 031069-81-5 Butyl acrylate-ethyl acrylate-methacrylic acid, copolymer - To be fixed
- 028159-98-0 2-(tert-Butylamino)-4-(cyclopropylamino)-6-(methylthio)-1,3,5-triazine - To be fixed
- 001948-33-0 2-tert-Butylhydroquinone - To be fixed
- 081869-18-3 N-(3-Carboxy-2-sulphopropionyl)-N-octadecenyl-DL-aspartic acid, tetrasodium salt - To be fixed
- 038916-42-6 N-(3-Carboxy-2-sulphopropionyl)-N-octadecyl-DL-aspartic acid, tetrasodium salt - To be fixed
- 003401-73-8 N-(3-Carboxy-2-sulphopropionyl)-N-octadecyl-L-aspartic acid, tetrasodium salt - To be fixed
- 009000-40-2 Carob gum - To be fixed
- 007775-09-9 Chloric acid, sodium salt - To be fixed
43470 011129-18-3 Cerium oxide 8 To be fixed
- 009012-76-4 Chitosan - To be fixed
- 001318-59-8 Chlorite group minerals - To be fixed
Chloroacetic acid, sodium salt, reaction products with N-alkyl(C8-C22)trimethylene-
46

- 097659-51-3 - To be fixed
diamines
Chloroacetic acid, sodium salt, reaction products with 1-(2-hydroxyethyl)-2-imida-
- 068608-65-1 - To be fixed
zoline 2-norcoco alkyl derivatives and sodium hydroxide
- 005915-41-3 2-Chloro-4-ethylamino-6-tert-butylamino-1,3,5-triazine - To be fixed
- 015733-22-9 p-Chloro-m-cresol, sodium salt - To be fixed
- 034911-46-1 2-Chloro-4'-hydroxy-2-isonitrosoacetophenone - To be fixed
- 132186-00-6 3-Chloro-2-hydroxypropyl-N,N,N-tripropylammonium chloride - To be fixed
- 061790-57-6 Cocoalkylamines, acetates - To be fixed
- 068953-13-9 Cocoalkylamines, acetates, reaction products with bentonite - To be fixed
- 061788-90-7 Cocoalkyldimethylamines, N-oxides - To be fixed
N-Cocoalkyl-3-sulphosuccinamic acid, monosodium salts, compounds with
- 084501-44-0 - To be fixed
triethanolamine
- 061791-63-7 N-Cocoalkyltrimethylenediamines - To be fixed
- 061791-64-8 N-Cocoalkyltrimethylenediamines, acetates - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
061790-63-4
45040 068440-04-0 Coconut oil fatty acids diethanolamide 7 To be fixed
068603-42-9
- 000101-83-7 N-Cyclohexylcyclohexylamine - To be fixed
- 000541-02-6 Decamethylcyclopentasiloxane - To be fixed
- 036362-09-1 2-(Decylthio)ethylamine hydrochloride - To be fixed
- 000135-57-9 2,2'-Dibenzamidodiphenyl disulphide - To be fixed
- 003252-43-5 Dibromoacetonitrile - To be fixed
- 073003-80-2 2,2-Dibromopropanediamide - To be fixed
- 000109-46-6 N,N'-Dibutylthiourea - To be fixed
- 096633-68-0 Dibutyltin bis(coco acyloxy) derivatives - To be fixed
47220 000077-58-7 Dibutyltin dilaurate 8 To be fixed
47265 000095-50-1 1,2-Dichlorobenzene 7 To be fixed
47360 000075-71-8 Dichlorodifluoromethane 7 To be fixed
47

- 064359-81-5 4,5-Dichloro-2-octyl-4-isothiazolin-3-one - To be fixed

- 000078-87-5 1,2-Dichloropropane - To be fixed
- 000067-43-6 Diethylenetriaminepentaacetic acid - To be fixed
- 068399-63-3 Diethylenetriaminetetra(methylenephosphonic acid), sodium salt - To be fixed
48370 000100-37-8 Diethylethanolamine 8 To be fixed
- 000105-55-5 N,N'-Diethylthiourea - To be fixed
- 000075-10-5 Difluoromethane - To be fixed
- 001322-93-6 Diisopropylnaphthalenesulphonic acid, sodium salt - To be fixed
- 000109-87-5 Dimethoxymethane - To be fixed
- 003845-76-9 N-(Dimethylaminopropyl)acrylamide - To be fixed
2,2'-[[6-(Dimethylamino)-1,3,5-triazin-2,4-diyl]bis(imino-4,1-phenyleneimino-4,1-
- 174514-06-8 - To be fixed
phenyleneazo)]bis(1,3-dimethyl-1H-imidazolium) dichloride
- 007473-98-5 2,2-Dimethyl-2-hydroxyacetophenone - To be fixed
- 000128-03-0 Dimethyldithiocarbamic acid, potassium salt - To be fixed
- 001643-20-5 N,N-Dimethyldodecylamine oxide - To be fixed
49465 000068-12-2 Dimethylformamide 6B To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 000107-54-0 3,5-Dimethyl-1-hexyn-3-ol - To be fixed
- 000077-71-4 5,5-Dimethylhydantoin - To be fixed
- 055121-81-8 Dimethyloctadecylbenzenesulphonic acid - To be fixed
- 068308-74-7 N,N-Dimethyl tall oil fatty amides - To be fixed
- 068988-89-6 [(Dimethylvinylsilyl)oxy]silica and [(trilethylsilyl)oxy]silica, modified - To be fixed
- 041319-54-4 Dioctadecylcarbamoyl chloride - To be fixed
51160 000123-91-1 Dioxane 6A To be fixed
51360 068442-68-2 Diphenylamine, styrenated 9 To be fixed
51870 034590-94-8 Dipropyleneglycol monomethyl ether 8 To be fixed
- 064742-30-9 Distillates (petroleum), chemically neutralized middle - To be fixed
- 064742-80-9 Distillates (petroleum), hydrodesulfurized middle - To be fixed
- 064742-52-5 Distillates (petroleum), hydrotreated heavy naphthenic - To be fixed
- 064742-54-7 Distillates (petroleum), hydrotreated heavy paraffinic - To be fixed
- 064742-53-6 Distillates (petroleum), hydrotreated light naphthenic - To be fixed
48

- 064742-55-8 Distillates (petroleum), hydrotreated light paraffinic - To be fixed

- 064742-46-7 Distillates (petroleum), hydrotreated middle - To be fixed
- 064742-65-0 Distillates (petroleum), solvent-dewaxed heavy paraffinic - To be fixed
- 064741-96-4 Distillates (petroleum), solvent-refined heavy naphthenic - To be fixed
- 064741-88-4 Distillates (petroleum), solvent-refined heavy paraffinic - To be fixed
- 064741-91-9 Distillates (petroleum), solvent-refined middle - To be fixed
- 064741-97-5 Distillates (petroleum), solvent-refined light naphthenic - To be fixed
- 064741-89-5 Distillates (petroleum), solvent-refined light paraffinic - To be fixed
- 064742-91-2 Distillates (petroleum), steam-cracked - To be fixed
- 064741-44-2 Distillates (petroleum), straight-run middle - To be fixed
- 064741-86-2 Distillates (petroleum), sweetened middle - To be fixed
- 000112-40-3 Dodecane - To be fixed
- 068526-91-0 Dodecene, hydroformylation products, high-boiling - To be fixed
- 000123-01-3 Dodecylbenzene - To be fixed
- 053520-67-5 Eicosenylsuccinic anhydride - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 068797-57-9 Epichlorohydrin-imidazole, copolymer - To be fixed
- 025988-98-1 Epichlorohydrin-N,N,N',N'-tetramethylethylenediamine, copolymer - To be fixed
- 000106-88-7 1,2-Epoxybutane - To be fixed
52685 002530-83-8 [3-(2,3-Epoxypropoxy)propyl]trimethoxysilane 6A To be fixed
2,3-Epoxypropyl methacrylate - 2-ethoxyethyl acrylate - N-methylperfluorooctane-
- 092265-81-1 sulphonamidoethyl acrylate - trimethylethanolammonium chloride methacrylate, - To be fixed
copolymer
- 007747-35-5 5-Ethyl-1-aza-3,7-dioxabicyclo[3.3.0]octane - To be fixed
- 000142-59-6 Ethylenebis(dithiocarbamic acid), disodium salt - To be fixed
- 001429-50-1 Ethylenediaminetetra(methylenephosphonic acid) - To be fixed
- 022036-77-7 Ethylenediaminetetra(methylenephosphonic acid), sodium salt - To be fixed
- 026795-67-5 Ethylene oxide-morpholine, copolymer - To be fixed
- 068609-68-7 2-Ethylhexanol, manuf. of, by-products from, distillation residues - To be fixed
- 000141-98-0 Ethylthiocarbamic acid, O-isopropyl ester - To be fixed
49

- 068953-19-5 Fatty acids, coco, esters with propyleneglycol - To be fixed

- 061791-00-2 Fatty acids, tall oil, ethoxylated - To be fixed
- 068309-16-0 Fatty acids, tall oil, monoesters with diethyleneglycol - To be fixed
- 061790-69-0 Fatty acids, tall oil, reaction products with diethylenetriamine - To be fixed
- 068334-18-9 Fatty acids, tall oil, tetraesters with pentaerythritol - To be fixed
- 094581-09-6 Fatty acids, tall oil, triesters with trimethylolpropane - To be fixed
- 099035-71-9 Fish oil, hydrogenated, sulphonated, sodium salts - To be fixed
- 184539-90-0 Formaldehyde-melamine-starch, copolymer - To be fixed
- 068037-07-0 Formaldehyde, polymers with sulphonated phenol, sodium salts - To be fixed
- 085338-22-3 Formaldehyde, reaction products with propyleneglycol - To be fixed
- 009000-28-6 Ghatti gum - To be fixed
- 071195-64-7 Glutaric acid, diisobutyl ester - To be fixed
55880 001119-40-0 Glutaric acid, dimethyl ester 7 To be fixed
- 067701-27-3 Glycerol esters of C14-C18 acids - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
58000 068476-38-0 Glycerol trimontanate 7 To be fixed
- 000593-85-1 Guanidine, carbonate - To be fixed
- 005423-22-3 Guanidine, phosphate - To be fixed
- 039454-79-0 Guar gum, carboxymethyl, 2-hydroxypropyl ether - To be fixed
- 078615-64-2 Guar gum, dihydrogen phosphate - To be fixed
- 065497-29-2 Guar gum, 2-hydroxy-3-(trimethylammonio)propyl ether, chloride - To be fixed
- 012173-47-6 Hectorite - To be fixed
- 009025-56-3 Hemicellulase - To be fixed
2-(8-Heptadecenyl)-4,5-dihydro-1-methyl-3-[2-[(1-oxo-9-octadecenyl)amino]ethyl]-
- 094944-77-1 - To be fixed
(z,z)-1H-imidazolium methyl sulphate
- 027136-73-8 2-(Heptadecenyl)-1-(2-hydroxyethyl)imidazoline - To be fixed
- 000506-52-5 1-Hexacosanol - To be fixed
1-Hexadecene - methoxypolyethyleneglycol monobutenedioate - 1-tetradecene,
- 138063-67-9 - To be fixed
polymer
50

- 054111-93-2 Hexadecenylsuccinic acid - To be fixed

- 061412-52-0 2-Hexadecenylsuccinic acid - To be fixed
- 083763-21-7 15-Hexadecenylsuccinic acid - To be fixed
- 053473-28-2 Hexamethylenediaminetetra(methylenephosphonic acid), hexapotassium salt - To be fixed
- 038820-59-6 Hexamethylenediaminetetra(methylenephosphonic acid), potassium salt - To be fixed
- 024360-05-2 Hexamethylenetetramine hydrochloride - To be fixed
- 068937-28-0 1,6-Hexanediol, distillation overheads - To be fixed
- 267233-83-0 Hydrocarbons, resins, coumarin-indene - To be fixed
- 267233-62-5 Hydrocarbons, resins, cyclodiene - To be fixed
- 000111-41-1 N-(2-Hydroxyethyl)ethylenediamine - To be fixed
60640 000150-39-0 N-(2-Hydroxyethyl)ethylenediaminetriacetic acid 8 To be fixed
- 002809-21-4 1-Hydroxyethylidenediphosphonic acid - To be fixed
- 029329-71-3 1-Hydroxyethylidenediphosphonic acid, sodium salt - To be fixed
- 003794-83-0 1-Hydroxyethylidenediphosphonic acid, tetrasodium salt - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
61055 000122-99-6 2-Hydroxyethyl phenyl ether 8 To be fixed
- 000126-11-4 2-(Hydroxymethyl)-2-nitro-1,3-propanediol - To be fixed
- 013824-96-9 Hypobromous acid, sodium salt - To be fixed
Imidazolium compounds, 2-C4-C8-alkyl-1-(2-carboxyethyl)-4,5-dihydro-
- 070983-43-6 - To be fixed
3-(hydroxyethyl), hydroxides, sodium salts
Imidazolium compounds, 1-[2-(carboxymethoxy)ethyl]-1-(carboxymethyl)-4,5-dihy-
- 068650-39-5 - To be fixed
hydro-2-norcoco alkyl, hydroxides, inner salts, disodium salts
Imidazolium compounds, 1(or 3)-(carboxymethyl)-4,5-dihydro-1-(hydroxyethyl)-
- 068647-53-0 - To be fixed
2-norcoco alkyl, hydroxides, monosodium salts
Imidazolium compounds, 4,5-dihydro-1-methyl-2-nortallow alkyl-1-(2-tallow amido-
- 068122-86-1 - To be fixed
ethyl), methyl sulphates
Imidazolium compounds, 4,5-dihydro-1-methyl-2-nortallow alkyl-3-(2-tallow amido-
- 086088-85-9 - To be fixed
ethyl), methyl sulphates
- 009025-67-6 Inulinase - To be fixed
- 000089-65-6 Isoascorbic acid - To be fixed
51

(19120) 025339-17-7 Isodecanol 8 To be fixed

- 027458-93-1 Isooctadecanol - To be fixed
- 000123-51-3 Isopentanol - To be fixed
- 002210-25-5 N-Isopropylacrylamide - To be fixed
- 000556-61-6 Isothiocyanic acid, methyl ester - To be fixed
- 122625-12-1 Itaconic acid-vinyl acetate, hydrolyzed, sodium salt, copolymer - To be fixed
- 008016-28-2 Lard oil - To be fixed
- 068440-40-4 Lard oil, methyl esters, sulphurized - To be fixed
63970 005989-27-5 D-Limonene 8 To be fixed
- 009001-62-1 Lipase - To be fixed
- 101316-70-5 Lubricating oils (petroleum), C17-C32, solvent-extd., dewaxed, hydrogenated - To be fixed
- 092045-42-6 Lubricating oils (petroleum), C17-C35, solvent-extd., dewaxed, hydrotreated - To be fixed
- 083987-85-2 Magnesite, calcined - To be fixed
- 000142-16-5 Maleic acid, bis(2-ethylhexyl) ester - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 068186-70-9 Maleic acid, isodecyl ester - To be fixed
(19977) 000060-24-2 2-Mercaptoethanol 8 To be fixed
(20860) 005039-78-1 Methacrylic acid, ester with trimethylethanolammonium chloride 8 To be fixed
- 032435-46-4 Methacrylic acid, 2-hydroxyethyl ester, hydrogen phosphate - To be fixed
- 028430-58-2 Methacrylic acid-methyl methacrylate-vinyl acetate, copolymer - To be fixed
- 000075-75-2 Methanesulphonic acid - To be fixed
- 030388-01-3 Methanethiosulphonic acid, 2-hydroxypropyl ester - To be fixed
- 000625-45-6 Methoxyacetic acid - To be fixed
66030 000150-76-5 4-Methoxyphenol 8 To be fixed
(20785) 026915-72-0 Methoxypolyethyleneglycol monomethacrylate 8 To be fixed
- 000134-84-9 4-Methylbenzophenone - To be fixed
- 062258-49-5 2-Methyl-2-butene - alpha-methylstyrene - 1,3-pentadiene, copolymer - To be fixed
- 026813-14-9 2-Methyl-2-butene - 1,3-pentadiene, copolymer - To be fixed
- 000137-32-6 2-Methyl-1-butanol - To be fixed
52

- 000583-59-5 2-Methylcyclohexanol - To be fixed

- 000074-87-3 Methyl chloride - To be fixed
- 002565-36-8 2,2'-Methylenebis(oxyethanol) - To be fixed
- 026172-54-3 2-Methyl-4-isothiazolin-3-one hydrochloride - To be fixed
66800 000139-99-1 Methyl oleate, sulphated D To be fixed
66860 000108-11-2 4-Methyl-2-pentanol 8 To be fixed
- 000611-15-4 2-Methylstyrene - To be fixed
(22242) 006144-04-3 alpha-Methylstyrene, dimer D To be fixed
- 002031-67-6 Methyltriethoxysilane - To be fixed
- 068308-60-1 Mixture of lard oil, palm oil, soybean oil and tallow oil, hydrogenated - To be fixed
- 097593-30-1 Mono- and diglycerides of fatty acids (C8-C21 and C8-C21 unsaturated) - To be fixed
- 067701-33-1 Mono- and diglycerides of fatty acids (C14-C18) - To be fixed
67345 085251-77-0 Mono- and diglycerides of fatty acids (C16-C18) 9 To be fixed
- 068424-61-3 Mono- and diglycerides of fatty acids (C16-C18 and C18 unsaturated) - To be fixed
(22340) 000074-89-5 Monomethylamine W8 To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 073138-43-9 Montan wax fatty acids, compounds with triethanolamine - To be fixed
- 065229-24-5 Myristic acid, pentahydroxydichromium salt - To be fixed
- 000091-20-3 Naphthalene - To be fixed
67910 000085-47-2 1-Naphthalenesulphonic acid 8 To be fixed
- 068153-01-5 Naphthalenesulphonic acids - To be fixed
- 003251-23-8 Nitric acid, copper(II) salt - To be fixed
- 000139-13-9 Nitrilotriacetic acid - To be fixed
- 005064-31-3 Nitrilotriacetic acid, trisodium salt - To be fixed
- 006419-19-8 Nitrilotris(methylenephosphonic acid) - To be fixed
- 002235-43-0 Nitrilotris(methylenephosphonic acid), pentasodium salt - To be fixed
- 094021-23-5 Nitrilotris(methylenephosphonic acid), tetrasodium salt - To be fixed
- 000557-61-9 1-Octacosanol - To be fixed
- 000112-88-9 1-Octadecene - To be fixed
- 028299-29-8 Octadecenylsuccinic acid - To be fixed
53

- 028805-58-5 Octenylsuccinic acid - To be fixed

- 094386-55-7 7-Octenylsuccinic acid - To be fixed
- 026530-20-1 2-Octyl-4-isothiazolin-3-one - To be fixed
(22690) 001806-26-4 4-Octylphenol 8 To be fixed
Oleic acid, reaction products with diethylenetriamine, cyclized, diethyl sulphate-
- 068511-92-2 - To be fixed
quaternized
- 068988-76-1 Oleic acid, sulphonated - To be fixed
- 007173-62-8 N-Oleyl-1,3-diaminopropane - To be fixed
- 025307-17-9 N-Oleyldiethanolamine - To be fixed
- 068514-74-9 Palm oil, hydrogenated - To be fixed
71120 008012-95-1 Paraffin oil 9 To be fixed
- 064742-43-4 Paraffin waxes (petroleum), clay-treated - To be fixed
- 064771-71-7 Paraffins (petroleum), normal C>10 - To be fixed
- 013081-97-5 Pentaerythritol distearate - To be fixed
- 051728-26-8 Pentaerythritol ethoxylate tetraacrylate - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 000354-33-6 Pentafluoroethane - To be fixed
- 068310-75-8 (Perfluorooctylsulphonylaminopropyl)trimethylammonium iodide - To be fixed
- 000614-45-9 Peroxybenzoic acid, tert-butyl ester - To be fixed
- 010058-23-8 Peroxymonosulphuric acid, monopotassium slt - To be fixed
- 068610-06-0 Phenol, isobutylenated - To be fixed
- 004169-04-4 2-Phenoxy-1-propanol - To be fixed
- 013598-36-2 Phosphonic acid - To be fixed
- 021056-98-4 Phosphonic acid, calcium salt - To be fixed
- 037971-36-1 2-Phosphono-1,2,4-butanetricarboxylic acid - To be fixed
- 053126-06-0 Phosphoric acid, butyl ester, potassium salt - To be fixed
- 000107-66-4 Phosphoric acid, dibutyl ester - To be fixed
- 084962-20-9 Phosphoric acid, mixed esters with 1-butanol and ethyleneglycol - To be fixed
- 001623-15-0 Phosphoric acid, monobutyl ester - To be fixed
- 068427-32-7 Phosphoric acid, monodecyl ester, potassium salt - To be fixed
- 010294-56-1 Phosphorous acid - To be fixed
54

74800 068515-42-4 Phthalic acid, dialkyl(C7-C11) esters 6B To be fixed

75280 000084-69-5 Phthalic acid, diisobutyl ester 6B To be fixed
76005 000085-70-1 Phthalic acid, mixed esters with butyl glycolate and butanol 6B To be fixed
- 000643-79-8 Phthalic aldehyde - To be fixed
76445 009003-05-8 Polyacrylamide 9 To be fixed
76461 009003-01-4 Polyacrylic acid 7 To be fixed
- 060864-33-7 Polyethyleneglycol benzyl (1,1,3,3-tetramethylbutyl)phenyl ethers - To be fixed
(11170) 026570-48-9 Polyethyleneglycol diester of acrylic acid 8 To be fixed
(20470) 025852-47-5 Polyethyleneglycol dimethacrylate 8 To be fixed
- 059269-54-4 Polyethyleneglycol dodecylphenyl ether sodium sulphate - To be fixed
- 068476-04-0 Polyethyleneglycolesters of montan wax fatty acids - To be fixed
- 073038-25-2 Polyethyleneglycol isotridecyl ether phosphate - To be fixed
- 068130-47-2 Polyethyleneglycol monoalkyl(C8-C10) ether phosphate - To be fixed
(21205) 025736-86-1 Polyethyleneglycol monomethacrylate 7 To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 174200-85-2 Polyethyleneglycol monomethacrylate 2,4,6-tris(styryl)phenyl ether - To be fixed
- 068891-39-4 Polyethyleneglycol nonylphenyl ether, branched, sodium sulphate - To be fixed
78480 051811-79-1 Polyethyleneglycol nonylphenyl ether phosphate 9 To be fixed
78460 009014-90-8 Polyethyleneglycol nonylphenyl ether sodium sulphate P To be fixed
- 052623-95-7 Polyethyleneglycol octylphenyl ether phosphate - To be fixed
- 055348-40-8 Polyethyleneglycol tert-octylphenyl ether sodium sulphate - To be fixed
- 058853-83-1 Polyethyleneglycol 4-octylphenyl ether sodium sulphate - To be fixed
- 109909-39-9 Polyethyleneglycol 2,4,6-triisobutylphenyl ether sodium sulphate - To be fixed
- 068131-73-7 Polyethylenepolyamines - To be fixed
- 093571-73-4 Polyethylenepolyamines, diethylenetriamine fraction, distillation residues - To be fixed
79920 009003-11-6 Poly(ethylene propylene)glycol 9 To be fixed
- 009041-33-2 Poly(ethylene propylene)glycol allyl ether - To be fixed
- 052232-27-6 Poly(ethylene propylene)glycol allyl methyl ether - To be fixed
- 037311-00-5 Poly(ethylene propylene)glycol dodecyl ether - To be fixed
55

- 068987-81-5 Poly(ethylene propylene)glycol ethers of C6-C10 alcohols - To be fixed

- 068603-25-8 Poly(ethylene propylene)glycol ethers of C8-C10 alcohols - To be fixed
- 068154-97-2 Poly(ethylene propylene)glycol ethers of C10-C12 alcohols - To be fixed
- 069227-21-0 Poly(ethylene propylene)glycol ethers of C12-C18 alcohols - To be fixed
- 011111-34-5 Poly(ethylene propylene)glycol ether of ethylenediaminetetrapropanol - To be fixed
- 009038-43-1 Poly(ethylene propylene)glycol octadecyl ether - To be fixed
- 061725-89-1 Poly(ethylene propylene)glycol tridecyl ether - To be fixed
- - Polymers of MW > 10,000 made of monomers of appendices A, B and C - To be fixed
- 009016-87-9 Poly(methylene phenylene isocyanate) - To be fixed
82050 000108-32-7 Propylene carbonate 8 To be fixed
- 068551-11-1 Propylene, hydroformylation products, high-boiling - To be fixed
80985 037281-78-0 Polypropyleneglycol oleate butyl ether 9 To be fixed
- 009015-54-7 Protein hydrolyzates - To be fixed
- 012211-28-8 Proteinase, Bacillus subtilis, sutilains - To be fixed
- 007681-57-4 Pyrosulfurous acid, sodium salt - To be fixed
- 000123-75-1 Pyrrolidine - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
Quaternary ammonium compounds, alkyl(C12-C16 branched and linear)ethyl-
- 085566-47-8 - To be fixed
dimethyl, ethyl sulphates
Quaternary ammonium compounds, benzylbis(hydrogenated tallow alkyl)methyl,
- 068153-30-0 - To be fixed
chlorides, compounds with bentonite
Quaternary ammonium compounds, benzylbis(hydrogenated tallow alkyl)methyl,
- 097952-68-6 - To be fixed
salts with montmorillonite
Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl,
- 061789-72-8 - To be fixed
chlorides
Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl,
83530 071011-24-0 9 To be fixed
chlorides, compounds with bentonite
Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl,
- 071011-25-1 chlorides, compounds with bentonite and bis(hydrogenated tallow alkyl)dimethyl- - To be fixed
ammonium chlorides
Quaternary ammonium compounds, benzyl(hydrogenated tallow alkyl)dimethyl,
83500 071011-26-2 9 To be fixed
chlorides, compounds with hectorite
Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl,
- 061789-80-8 - To be fixed
chlorides
56

Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl,

- 071011-27-3 - To be fixed
chlorides, compounds with hectorite
Quaternary ammonium compounds, bis(hydrogenated tallow alkyl)dimethyl,
83560 068953-58-2 9 To be fixed
chlorides,salts with bentonite
- 094891-31-3 Quaternary ammonium compounds, dialkyl(C16-C18)dimethyl, salts with hectorite - To be fixed
- 163479-06-9 Quaternary ammonium compounds, trimethyltallow alkyl, salts with montmorillonite - To be fixed
- 064741-67-9 Residues (petroleum), catalytic reformer fractionator - To be fixed
- 092202-14-7 Rosin, fumarated, reaction products with glycerol and pentaerythritol - To be fixed
- 068002-57-3 Rosin, reaction products with triethanolamine - To be fixed
- 068918-19-4 Rosin, sulphurized - To be fixed
84720 000118-58-1 Salicylic acid, benzyl ester 7 To be fixed
84960 000118-55-8 Salicylic acid, phenyl ester 7 To be fixed
- 064742-61-6 Slack wax (petroleum) - To be fixed
- 090669-78-6 Slack wax (petroleum), clay-treated - To be fixed
- 012199-37-0 Smectite-group minerals - To be fixed
- 007631-94-9 Sodium dithionate - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 007681-49-4 Sodium fluoride - To be fixed
- 011084-85-8 Sodium hypochlorite phosphate - To be fixed
- 064742-94-5 Solvent naphtha (petroleum), heavy aromatic - To be fixed
- 064742-88-7 Solvent naphtha (petroleum), medium aliphatic - To be fixed
- 036521-89-8 Sorbitan distearate - To be fixed
87440 071902-01-7 Sorbitan isostearate 9 To be fixed
87880 008007-43-0 Sorbitan sesquioleate 7 To be fixed
- 051938-44-4 Sorbitan sesquistearate - To be fixed
- 008016-70-4 Soybean oil, hydrogenated - To be fixed
89150 010119-53-6 Stearic acid, cerium salt 8 To be fixed
90000 000646-13-9 Stearic acid, isobutyl ester 7 To be fixed
90320 002778-96-3 Stearic acid, octadecyl ester 7 To be fixed
90640 031556-45-3 Stearic acid, tridecyl ester 7 To be fixed
- 008052-41-3 Stoddard solvent - To be fixed
91135 000106-65-0 Succinic acid, dimethyl ester 7 To be fixed
57

(24885) 005329-14-6 Sulphamic acid 8 To be fixed

Sulphonic acids, C10-C16-alkane hydroxy and C12-C20-alkapolyene and
- 068957-15-3 - To be fixed
C10-C16-alkene and C12-C20-alkene hydroxy, sodium salts
- 068439-57-6 Sulphonic acids, C14-C16-alkane hydroxy and C14-C16-alkene, sodium salts - To be fixed
- 061789-86-4 Sulphonic acids, petroleum, calcium salts - To be fixed
91520 005138-18-1 Sulphosuccinic acid 8 To be fixed
- 013419-59-5 Sulphosuccinic acid, trisodium salt - To be fixed
91560 002373-38-8 Sulphosuccinic acid, bis(1,3-dimethylbutyl) ester, sodium salt 6B To be fixed
91570 010041-19-7 Sulphosuccinic acid, bis(2-ethylhexyl) ester 6B To be fixed
91572 000577-11-7 Sulphosuccinic acid, bis(2-ethylhexyl) ester, sodium salt D To be fixed
- 006001-97-4 Sulphosuccinic acid, bis(1-methylpentyl) ester, sodium salt - To be fixed
91580 023386-52-9 Sulphosuccinic acid, dicyclohexyl ester, sodium salt 8 To be fixed
91650 000127-39-9 Sulphosuccinic acid, diisobutyl ester, sodium salt 6B To be fixed
91672 055184-72-0 Sulphosuccinic acid, diisotridecyl ester, sodium salt 6B To be fixed
91720 000922-80-5 Sulphosuccinic acid, dipentyl ester, sodium salt 6B To be fixed
91780 067893-42-9 Sulphosuccinic acid, 4-[2-[(12-hydroxy-1-oxooleyl)amino]ethyl] ester, disodium salt W8 To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
91800 037294-49-8 Sulphosuccinic acid, isodecyl ester, disodium salt 6B To be fixed
- 010124-43-3 Sulphuric acid, cobalt(II) salt - To be fixed
- 000077-78-1 Sulphuric acid, dimethyl ester - To be fixed
- 007782-99-2 Sulphurous acid - To be fixed
- 061790-33-8 Tallow alkyl amines - To be fixed
- 061790-60-1 Tallow alkyl amines, acetates - To be fixed
- 061791-26-2 Tallow alkyl amines, ethoxylated - To be fixed
- 008030-78-2 Tallow alkyltrimethylammonium chloride - To be fixed
- 061791-55-7 N-Tallow alkyltrimethylenediamines - To be fixed
- 061791-54-6 N-Tallow alkyltrimethylenediamines, acetates - To be fixed
- 061790-85-0 N-Tallow alkyltrimethylenediamines, ethoxylated - To be fixed
- 091079-23-1 Tallow oil - To be fixed
- 267233-96-5 Terpenes and terpenoids, turpentine-oil, polymerized - To be fixed
- 008000-41-7 Terpineol - To be fixed
- 000127-18-4 Tetrachloroethylene - To be fixed
58

- 076386-13-5 1-Tetradecenylsuccinic acid - To be fixed

- 058338-68-4 2-Tetradecenylsuccinic acid - To be fixed
- 032582-32-4 2-Tetradecyl-1-octadecanol - To be fixed
- 064253-30-1 Tetraethyleneglycol bis(dodecylthiopropionate) - To be fixed
- 000811-97-2 1,1,1,2-Tetrafluoroethane - To be fixed
- 002207-75-2 1,4,5,6-Tetrahydro-4,6-dioxo-1,3,5-triazine-2-carboxylic acid, monopotassium salt - To be fixed
92450 000097-99-4 Tetrahydrofurfurol 8 To be fixed
- 019798-93-7 Tetrahydro-6-phenyl-2H-1,3-oxazine - To be fixed
- 005395-50-6 Tetrakis(hydroxymethyl)glycoluril - To be fixed
- 017464-88-9 Tetrakis(methoxymethyl)glycoluril - To be fixed
- 003555-47-3 Tetrakis(trimethylsiloxy)silane - To be fixed
(25185) 000140-66-9 4-(1,1,3,3-Tetramethylbutyl)phenol 6B To be fixed
92685 000126-86-3 2,4,7,9-Tetramethyl-5-decyne-4,7-diol 8 To be fixed
- 000110-18-9 N,N,N',N'-Tetramethylethylenediamine - To be fixed
- 011117-11-6 Tetrapropylenebenzenesulphonic acid, calcium salt - To be fixed
92740 011067-82-6 Tetrapropylenebenzenesulphonic acid, sodium salt 8 To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
(25201) 000111-48-8 Thiodiethyleneglycol 8 To be fixed
- 010595-72-9 Thiodipropionic acid, ditridecyl ester - To be fixed
- 010101-88-9 Thiophosphoric acid, trisodium salt - To be fixed
- 004189-44-0 Thiourea S,S-dioxide - To be fixed
- 028804-47-9 Toluenesulphonic acid, methyl ester - To be fixed
- 000593-50-0 1-Triacontanol - To be fixed
- 081741-28-8 Tributyltetradecylphosphonium chloride - To be fixed
93840 000087-90-1 Trichlorocyanuric acid D To be fixed
93920 000075-69-4 Trichlorofluoromethane 7 To be fixed
- 003380-34-5 2,4,4'-Trichloro-2'-hydroxydiphenyl ether - To be fixed
- 068479-04-9 N-[3-(Tridecyloxy)propyl]-1,3-diaminopropane, branched - To be fixed
- 102047-27-8 N-[3-(Tridecyloxy)propyl]-1,3-diaminopropane, branched, monoacetate - To be fixed
- 014806-72-5 Triethanolamine acetate - To be fixed
- 027323-41-7 Triethanolamine dodecylbenzenesulphonate - To be fixed
- 068171-29-9 Triethanolamine tris(dihydrogen phosphate), sodium salt - To be fixed
59

- 090552-54-8 Triethoxyoctylsilane - To be fixed

94270 000121-44-8 Triethylamine 8 To be fixed
- 013150-00-0 Triethyleneglycol dodecyl ether sodium sulphate - To be fixed
- 025446-78-0 Triethyleneglycol tridecyl ether sodium sulphate - To be fixed
- 000420-46-2 1,1,1-Trifluoroethane - To be fixed
94480 026523-64-8 Trifluorotrichloroethane 7 To be fixed
- 001067-25-0 Trimethoxypropylsilane - To be fixed
- 000095-63-6 1,2,4-Trimethylbenzene - To be fixed
94880 000067-48-1 Trimethylethanolammonium chloride 8 To be fixed
- 000108-74-7 1,3,5-Trimethylhexahydro-1,3,5-triazine - To be fixed
- 041203-81-0 Trimethylolpropane cyclic methylphosphonate (1:1) methyl methylphosphonate - To be fixed
- 057675-44-2 1,1,1-Trimethylolpropane trioleate - To be fixed
- 068909-20-6 1,1,1-Trimethyl-N-(trimethylsilyl)silanamine, hydrolysis products with silica - To be fixed
- 003901-77-7 2,4,6-Trimethyl-2,4,6-trivinylcyclotrisiloxane - To be fixed
- 025498-49-1 Tripropyleneglycol monomethyl ether - To be fixed
- 004719-04-4 1,3,5-Tris(2-hydroxyethyl)hexahydro-1,3,5-triazine - To be fixed
 RESTRICTIONS
PM/REF No CAS No NAME SCF-L AND/OR
SPECIFICATIONS
- 090367-27-4 N,N,N'-Tris(2-hydroxyethyl)-N'-tallow alkyl-propylenediamine - To be fixed
- 018254-13-2 2,4,6-Tris(1-phenylethyl)phenol - To be fixed
(25950) 001852-04-6 Undecanedioic acid 8 To be fixed
- 093966-59-7 Urea sulphamate - To be fixed
- 025213-24-5 Vinyl acetate-vinyl alcohol, copolymer - To be fixed
- 068683-26-1 Vinyl acetate-vinyl neodecanoate, copolymer - To be fixed
60
 APPENDIX A

ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
10090 000064-19-7 Acetic acid 1 NS
(30140) 000141-78-6 Acetic acid, ethyl ester 1 NS
10120 000108-05-4 Acetic acid, vinyl ester 2 SML = 12 mg/kg 0,2
10630 000079-06-1 Acrylamide 4A SML = ND (DL = 0.01 mg/kg)
10660 015214-89-8 2-Acrylamido-2-methylpropanesulphonic acid 3 SML = 0.05 mg/kg
10690 000079-10-7 Acrylic acid 2 SML(T) = 6 mg/kg (11) 0,1
0.1 (as
SML(T) = 6 mg/kg (11)
10780 000141-32-2 Acrylic acid, n-butyl ester 2 acrylic
(as acrylic acid)
acid)
0.1 (as
SML(T) = 6 mg/kg (11)
10840 001663-39-4 Acrylic acid, tert-butyl ester 2 acrylic
(as acrylic acid)
acid)
61

11005 012542-30-2 Acrylic acid, dicyclopentenyl ester 3 SML = 0.05 mg/kg

11245 002156-97-0 Acrylic acid, dodecyl ester 3 SML = 0.05 mg/kg (1)
0.1 (as
SML(T) = 6 mg/kg (11)
11470 000140-88-5 Acrylic acid, ethyl ester 2 acrylic
(as acrylic acid)
acid)
11500 000103-11-7 Acrylic acid, 2-ethylhexyl ester 3 SML = 0.05 mg/kg
11530 000999-61-1 Acrylic acid, 2-hydroxypropyl ester 3 SML = 0.05 mg/kg
0.1 (as
SML(T) = 6 mg/kg (11)
11590 000106-63-8 Acrylic acid, isobutyl ester 2 acrylic
(as acrylic acid)
acid)
0.1 (as
SML(T) = 6 mg/kg (11)
11680 000689-12-3 Acrylic acid, isopropyl ester 2 acrylic
(as acrylic acid)
acid)
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
0.1 (as
SML(T) = 6 mg/kg (11)
11710 000096-33-3 Acrylic acid, methyl ester 2 acrylic
(as acrylic acid)
acid)
0.1 (as
SML(T) = 6 mg/kg
11830 000818-61-1 Acrylic acid, monoester with ethyleneglycol 2 acrylic
(as acrylic acid)
acid)
12100 000107-13-1 Acrylonitrile 4A SML = ND (DL= 0.01 mg/kg)
12130 000124-04-9 Adipic acid 1 5
12265 004074-90-2 Adipic acid, divinyl ester 3 SML(T) = 0.05 mg/kg (14)
Alcohols, aliphatic, monohydric, saturated, linear, primary
12375 - 3
(C4-C22)
12670 002855-13-2 1-Amino-3-aminomethyl-3,5,5-trimethylcyclohexane 2 SML = 6 mg/kg 0,1
12763 000141-43-5 2-Aminoethanol 3 SML = 0.05 mg/kg
12789 007664-41-7 Ammonia 1 NS
13090 000065-85-0 Benzoic acid 1 5
62

13390 000105-08-8 1,4-Bis(hydroxymethyl)cyclohexane 3

13395 004767-03-7 2,2-Bis(hydroxymethyl)propionic acid 3 SML = 0.05 mg/kg
13480 000080-05-7 2,2-Bis(4-hydroxyphenyl)propane 2 SML = 0.6 mg/kg 0.01
2,2-Bis(4-hydroxyphenyl)propane bis(2,3-epoxypropyl) ether
13510 001675-54-3 2-3 SML = 9 mg/kg 0.15
(= BADGE)
13630 000106-99-0 Butadiene 4A SML = ND (DL = 0.01 mg/kg)
13720 000110-63-4 1,4-Butanediol 3 SML = 5 mg/kg
SML(T) = ND (DL = 0.01
13780 002425-79-8 1,4-Butanediol bis(2,3-epoxypropyl) ether 4A mg/kg, as epoxy group,
Mw = 43) (15)
13840 000071-36-3 1-Butanol 3
13870 000106-98-9 1-Butene 3
13900 000107-01-7 2-Butene 3
14200 000105-60-2 Caprolactam 2 SML = 15 mg/kg 0,25
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
SML = 0.05 mg/kg (as the
14260 000502-44-3 Caprolactone 3 sum of caprolactone and
6-hydroxyhexanoic acid)
14411 008001-79-4 Castor oil 3
14500 009004-34-6 Cellulose 0
14800 003724-65-0 Crotonic acid 3 SML = 0.05 mg/kg
(45760) 000108-91-8 Cyclohexylamine 2 1
15250 000110-60-1 1,4-Diaminobutane 2 0,6
(46640) 000128-37-0 2,6-Di-tert-butyl-p-cresol (= BHT) 1 0,05
In compliance with the
- 000107-06-2 1,2-Dichloroethane -
FCC specifications
15695 000461-58-5 Dicyanodiamide 2 1
SML(T) = ND (DL = 0.01
15700 005124-30-1 Dicyclohexylmethane 4,4'-diisocyanate 4A
mg/kg, as NCO) (16)
15760 000111-46-6 Diethyleneglycol 2 SML(T) = 30 mg/kg (4) 0,5
63

15790 000111-40-0 Diethylenetriamine 3 SML = 5 mg/kg

(48800) 000097-23-4 2,2'-Dihydroxy-5,5'-dichlorodiphenylmethane 2 SML = 12 mg/kg 0,2
16090 000080-09-1 4,4'-Dihydroxydiphenylsulphone 3 SML = 0.05 mg/kg
16145 000124-40-3 Dimethylamine 3 SML = 0.06 mg/kg
16150 000108-01-0 Dimethylaminoethanol 2 SML = 18 mg/kg 0,3
16390 000126-30-7 2,2-Dimethyl-1,3-propanediol 3 SML = 0.05 mg/kg
16480 000126-58-9 Dipentaerythritol 2 1
SML(T) = ND (DL = 0.01
16600 005873-54-1 Diphenylmethane 2,4'-diisocyanate 4A
mg/kg, as NCO) (16)
SML(T) = ND (DL = 0.01
16630 000101-68-8 Diphenylmethane 4,4'-diisocyanate 4A
mg/kg, as NCO) (16)
000110-98-5
16660 Dipropyleneglycol 2 1,5
025265-71-8
SML = ND (DL = 0.01 mg/kg)
16690 001321-74-0 Divinylbenzene 4A
(9)
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
16697 000693-23-2 Dodecanedioic acid 3
16701 000112-53-8 1-Dodecanol 3
16704 000112-41-4 1-Dodecene 3 SML = 0.05 mg/kg
(52000) 025155-30-0 Dodecylbenzenesulphonic acid, sodium salt 2 SML = 30 mg/kg 0,5
16750 000106-89-8 Epichlorohydrin 4A SML = ND (DL = 0.01 mg/kg)
16780 000064-17-5 Ethanol 1
16950 000074-85-1 Ethylene 3
16960 000107-15-3 Ethylenediamine 2 SML = 12 mg/kg 0,2
16990 000107-21-1 Ethyleneglycol 2 SML(T) = 30 mg/kg (4) 0,5
17005 000151-56-4 Ethyleneimine 4A SML = ND (DL = 0.01 mg/kg)
17020 000075-21-8 Ethylene oxide 4A SML = ND (DL = 0.01 mg/kg)
17050 000104-76-7 2-Ethyl-1-hexanol 1 SML = 30 mg/kg 0,5
17236 064755-01-7 Fatty acids, tallow, calcium salts 3
17236 008052-48-0 Fatty acids, tallow, sodium salts 3
64

17260 000050-00-0 Formaldehyde 3 SML(T) = 15 mg/kg (6)

17275 000064-18-6 Formic acid 1 3
17290 000110-17-8 Fumaric acid 1 6
18010 000110-94-1 Glutaric acid 0
18100 000056-81-5 Glycerol 1 NS
(56960) 025496-72-4 Glycerol monooleate 1 NS
18115 031566-31-1 Glycerol monostearate 1 NS
18250 000115-28-6 Hexachloroendomethylenetetrahydrophthalic acid 4A SML = ND (DL = 0.01 mg/kg)
18280 000115-27-5 Hexachloroendomethylenetetrahydrophthalic anhydride 4A SML = ND (DL = 0.01 mg/kg)
18310 036653-82-4 1-Hexadecanol 3
18460 000124-09-4 Hexamethylenediamine 2 SML = 2.4 mg/kg 0,04
SML(T) = ND (DL = 0.01
18640 000822-06-0 Hexamethylene diisocyanate 4A
mg/kg, as NCO) (16)
SML(T) = 15 mg/kg (6)
18670 000100-97-0 Hexamethylenetetramine 3
(as formaldehyde)
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
18700 000629-11-8 1,6-Hexanediol 3 SML = 0.05 mg/kg
(59990) 007647-01-0 Hydrochloric acid 1 NS
18880 000099-96-7 4-Hydroxybenzoic acid 2 10
(62160) 007681-53-0 Hypophosphorous acid, sodium salt 3
19000 000115-11-7 Isobutene 3
1-Isocyanato-3-isocyanatomethyl-3,5,5- SML(T) = ND (DL = 0.01
19110 004098-71-9 4A
trimethylcyclohexane mg/kg, as NCO) (16)
19150 000121-91-5 Isophthalic acid 3 SML = 5 mg/kg
19270 000097-65-4 Itaconic acid 0
19460 000050-21-5 Lactic acid 1 NS
19480 002146-71-6 Lauric acid, vinyl ester 3
19518 000060-33-3 Linoleic acid 0
19540 000110-16-7 Maleic acid 2 SML(T) = 30 mg/kg (12) 0,5
SML(T) = 30 mg/kg (12)
19960 000108-31-6 Maleic anhydride 2 0,5
65

(as maleic acid)

19990 000079-39-0 Methacrylamide 4A SML = ND (DL = 0.01 mg/kg)
20020 000079-41-4 Methacrylic acid 2 SML(T) = 6 mg/kg (13) 0,1
20050 000096-05-9 Methacrylic acid, allyl ester 3 SML = 0.05 mg/kg
SML(T) = 6 mg/kg (13) 0.1 (as
20110 000097-88-1 Methacrylic acid, butyl ester 2
(as methacrylic acid) m. acid)
SML(T) = 6 mg/kg (13) 0.1 (as
20170 000585-07-9 Methacrylic acid, tert-butyl ester 2
(as methacrylic acid) m. acid)
20440 000097-90-5 Methacrylic acid, diester with ethyleneglycol 3 SML = 0.05 mg/kg
20530 002867-47-2 Methacrylic acid, 2-(dimethylamino)ethyl ester 4A SML = ND (DL = 0.01 mg/kg)
SML(T) = ND (DL = 0.01
20590 000106-91-2 Methacrylic acid, 2,3-epoxypropyl ester 4B mg/kg, as epoxy group,
Mw = 43) (15)
SML(T) = 6 mg/kg (13) 0.1 (as
20890 000097-63-2 Methacrylic acid, ethyl ester 2
(as methacrylic acid) m. acid)
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
SML(T) = 6 mg/kg (13) 0.1 (as
21010 000097-86-9 Methacrylic acid, isobutyl ester 2
(as methacrylic acid) m. acid)
SML(T) = 6 mg/kg (13) 0.1 (as
21130 000080-62-6 Methacrylic acid, methyl ester 2
(as methacrylic acid) m. acid)
SML(T) = 6 mg/kg (13) 0.1 (as
21190 000868-77-9 Methacrylic acid, monoester with ethyleneglycol 2
(as methacrylic acid) m. acid)
21370 010595-80-9 Methacrylic acid, 2-sulphoethyl ester 4A SML = ND (DL = 0.01 mg/kg)
21400 054276-35-6 Methacrylic acid, sulphopropyl ester 3 SML = 0.05 mg/kg
21490 000126-98-7 Methacrylonitrile 4A SML= ND (DL = 0.01 mg/kg)
21498 002530-85-0 [3-(Methacryloxy)propyl]trimethoxysilane 3 SML = 0.05 mg/kg
21520 001561-92-8 Methallylsulphonic acid, sodium salt 3 SML = 5 mg/kg
21550 000067-56-1 Methanol 3
(66120) 010605-21-7 Methyl benzimidazolecarbamate 2 SML = 0.6 mg/kg 0,01
21640 000078-79-5 2-Methyl-1,3-butadiene 4A SML = ND (DL = 0.01 mg/kg)
(66620) 000075-09-2 Methylene chloride 3 SML = 0.05 mg/kg
66

(66725) 000108-10-1 Methyl isobutyl ketone 3 SML = 5 mg/kg

21940 000924-42-5 N-Methylolacrylamide 4A SML = ND (DL = 0.01 mg/kg)
21970 000923-02-4 N-Methylolmethacrylamide 3 SML = 0.05 mg/kg
22210 000098-83-9 alpha-Methylstyrene 3 SML = 0.05 mg/kg
22555 000112-92-5 1-Octadecanol 3
22660 000111-66-0 1-Octene 2 SML = 15 mg/kg 0.25
22763 000112-80-1 Oleic acid 1 NS
22766 000143-28-2 Oleyl alcohol 3
22775 000144-62-7 Oxalic acid 2 SML = 6 mg/kg 0,1
22840 000115-77-5 Pentaerythritol 2 1
22870 000071-41-0 1-Pentanol 3
22960 000108-95-2 Phenol 2 1,5
23170 007664-38-2 Phosphoric acid 1 70 (as P)
23173 001314-56-3 Phosphoric anhydride 1 70 (as P)
23230 000131-17-9 Phthalic acid, diallyl ester 4A SML = ND (DL = 0.01 mg/kg)
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
23380 000085-44-9 Phthalic anhydride 2 1
23740 000057-55-6 1,2-Propanediol 1 25
23770 000504-63-2 1,3-Propanediol 3 SML = 0.05 mg/kg
SML(T) = 6 mg/kg (10)
23920 000105-38-4 Propionic acid, vinyl ester 2 0,1
(as acetaldehyde)
23980 000115-07-1 Propylene 3
24010 000075-56-9 Propylene oxide 4A SML = ND (DL = 0.01 mg/kg)
24055 000089-05-4 Pyromellitic acid 3 SML = 0.05 mg/kg
24070 073138-82-6 Resin acids and rosin acids 2 1
24100 008050-09-7 Rosin 2 1
SML(T) = 10 mg/kg (8) 0.7
(86480) 007631-90-5 Sodium bisulphite 1
(as SO2) (as SO2)
In compliance with the
- 007681-57-4 Sodium metabisulphite -
specifications of E223
SML(T) = 10 mg/kg (8) 0.7
67

(86960) 007757-83-7 Sodium sulphite 1

(as SO2) (as SO2)
(87600) 001338-39-2 Sorbitan monolaurate 1 5
(87760) 026266-57-9 Sorbitan monopalmitate 1 25
(88240) 026658-19-5 Sorbitan tristearate 1 25
24490 000050-70-4 Sorbitol 1
24550 000057-11-4 Stearic acid 1 NS
24610 000100-42-5 Styrene 4B To be fixed
24760 026914-43-2 Styrenesulphonic acid 3 SML = 0.05 mg/kg
24820 000110-15-6 Succinic acid 1 NS
24850 000108-30-5 Succinic anhydride 2 NS
24887 006362-79-4 5-Sulphoisophthalic acid, monosodium salt 3 SML = 5 mg/kg
24888 003965-55-7 5-Sulphoisophthalic acid, monosodium salt, dimethyl ester 3 SML = 0.05 mg/kg
(91920) 007664-93-9 Sulphuric acid 1 NS
24905 008002-26-4 Tall oil 3
24910 000100-21-0 Terephthalic acid 2 SML = 7.5 mg/kg 0,125
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
SML(T) = 7.5 mg/kg (expressed as
24940 000100-20-9 Tertephthalic acid dichloride 2 0.125
terephthalic acid)
24970 000120-61-6 Terephthalic acid, dimethyl ester 2 1
25120 000116-14-3 Tetrafluoroethylene 3 SML = 0.05 mg/kg
25150 000109-99-9 Tetrahydrofuran 2 SML = 0.6 mg/kg 0,01
25205 000108-88-3 Toluene 3 SML = 1.2 mg/kg
SML(T) = ND (DL = 0.01
25208 026471-62-5 Toluene diisocyanate 4A
mg/kg, as NCO) (16)
SML(T) = ND (DL = 0.01
25210 000584-84-9 2,4-Toluene diisocyanate 4A
mg/kg, as NCO) (16)
SML(T) = ND (DL = 0.01
25240 000091-08-7 2,6-Toluene diisocyanate 4A
mg/kg, as NCO) (16)
25420 000108-78-1 2,4,6-Triamino-1,3,5-triazine 2 SML = 30 mg/kg 0,5
25480 000102-71-6 Triethanolamine 3 SML = 0.05 mg/kg
25510 000112-27-6 Triethyleneglycol 2 5
68

SML = 5 mg/kg (as trimelli-

25550 000552-30-7 Trimellitic anhydride 3
tic acid)
25600 000077-99-6 1,1,1-Trimethylolpropane 2 SML = 6 mg/kg 0,1
25960 000057-13-6 Urea 0
26050 000075-01-4 Vinyl chloride 4A SML = ND (DL = 0.01 mg/kg)
26170 003195-78-6 N-Vinyl-N-methylacetamide 3 SML(T) = 0.05 mg/kg (14)
26305 000078-08-0 Vinyltriethoxysilane 3 SML = 0.05 mg/kg
26320 002768-02-7 Vinyltrimethoxysilane 3 SML(T) = 0.05 mg/kg (14)
26370 001330-20-7 Xylene 3 SML = 1.2 mg/kg
 APPENDIX B

ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION mg/kg
bw
11440 044992-01-0 Acrylic acid, ester with trimethylethanolammonium chloride 8 To be fixed
- 013106-44-0 Acrylic acid, ester with trimethylethanolammonium methyl sulphate - To be fixed
- 000106-74-1 Acrylic acid, 2-ethoxyethyl ester - To be fixed
- 025268-77-3 Acrylic acid, N-methylperfluorooctanesulphonamidoethyl ester - To be fixed
12235 000627-93-0 Adipic acid, dimethyl ester 6B To be fixed
(35200) 034730-59-1 N-(2-Aminoethyl)-2-aminoethanesulphonic acid, sodium salt 8 To be fixed
12769 013531-52-7 N-(2-Aminoethyl)-1,3-diaminopropane 8 To be fixed
12772 000140-31-8 N-Aminoethylpiperazine 8 To be fixed
13255 010563-26-5 N,N'-Bis(3-aminopropyl)ethylenediamine 8 To be fixed
- 000105-83-9 N,N-Bis(3-aminopropyl)methylamine - To be fixed
- 003327-22-8 (3-Chloro-2-hydroxypropyl)trimethylammonium chloride - To be fixed
69

- 007398-69-8 Diallyldimethylammonium chloride - To be fixed

16115 025167-70-8 Diisobutene 8 To be fixed
- 046830-22-2 Dimethyl(acryloyloxyethyl)benzylammonium chloride - To be fixed
16180 005205-93-6 N-(Dimethylaminopropyl)methacrylamide 6A To be fixed
- 003033-77-0 (2,3-Epoxypropyl)trimethylammonium chloride - To be fixed
18055 001119-40-0 Glutaric acid, dimethyl ester 7 To be fixed
18120 000107-22-2 Glyoxal 6A To be fixed
20860 005039-78-1 Methacrylic acid, ester with trimethylethanolammonium chloride 8 To be fixed
- 006891-44-7 Methacrylic acid, ester with trimethylethanolammonium methyl sulphate - To be fixed
20920 000688-84-6 Methacrylic acid, 2-ethylhexyl ester 8 To be fixed
- 000105-59-9 N-Methyldiethanolamine - To be fixed
(67910) 000085-47-2 1-Naphthalenesulphonic acid 8 To be fixed
(67912) 000120-18-3 2-Naphthalenesulphonic acid 8 To be fixed
- 004067-16-7 Pentaethylenehexamine - To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION mg/kg
bw
- 061788-44-1 Phenol, styrenated - To be fixed
- 000120-07-0 N-Phenyldiethanolamine - To be fixed
- 009004-74-4 Polyethyleneglycol monomethyl ether - To be fixed
25520 000112-24-3 Triethylenetetramine 8 To be fixed
- 000593-67-9 Vinylamine - To be fixed
- 013162-05-5 N-Vinylformamide - To be fixed
26230 000088-12-0 Vinylpyrrolidone 6A To be fixed
26260 001184-84-5 Vinylsulphonic acid 6A To be fixed
- 003039-83-6 Vinylsulphonic acid, sodium salt - To be fixed
70
 APPENDIX C

ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
- 000108-22-5 Acetic acid, isopropenyl ester - To be fixed
10157 000098-86-2 Acetophenone 8 To be fixed
- 002754-27-0 Acetoxytrimethylsilane - To be fixed
- 000107-02-8 Acrolein - To be fixed
- 045021-77-0. (3-Acrylamidopropyl)trimethylammonium chloride - To be fixed
10720 000999-55-3 Acrylic acid, allyl ester 6A To be fixed
- 024615-84-7 Acrylic acid, 2-carboxyethyl ester - To be fixed
10990 002156-96-9 Acrylic acid, decyl ester 7 To be fixed
11020 019485-03-1 Acrylic acid, diester with 1,3-butanediol 8 To be fixed
11050 001070-70-8 Acrylic acid, diester with 1,4-butanediol 8 To be fixed
11080 004074-88-8 Acrylic acid, diester with diethyleneglycol 8 To be fixed
71

11090 002223-82-7 Acrylic acid, diester with 2,2-dimethyl-1,3-propanediol 8 To be fixed

11100 057472-68-1 Acrylic acid, diester with dipropyleneglycol 8 To be fixed
11110 002274-11-5 Acrylic acid, diester with ethyleneglycol 8 To be fixed
11140 013048-33-4 Acrylic acid, diester with 1,6-hexanediol 8 To be fixed
11170 026570-48-9 Acrylic acid, diester with polyethyleneglycol 8 To be fixed
11180 017831-71-9 Acrylic acid, diester with tetraethyleneglycol 8 To be fixed
11190 001680-21-3 Acrylic acid, diester with triethyleneglycol 8 To be fixed
11195 042978-66-5 Acrylic acid, diester with tripropyleneglycol 8 To be fixed
068901-05-3
11200 002426-54-2 Acrylic acid, 2-(diethylamino)ethyl ester 8 To be fixed
11230 002439-35-2 Acrylic acid, 2-(dimethylamino)ethyl ester 7 To be fixed
11260 000106-90-1 Acrylic acid, 2,3-epoxypropyl ester 6A To be fixed
11520 002918-23-2 Acrylic acid, 2-hydroxyisopropyl ester 7 To be fixed
11560 005888-33-5 Acrylic acid, isobornyl ester 8 To be fixed
11650 029590-42-9 Acrylic acid, isooctyl ester 8 To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
11770 002478-10-6 Acrylic acid, monoester with 1,4-butanediol 8 To be fixed
11950 000937-41-7 Acrylic acid, phenyl ester 7 To be fixed
12058 003524-68-3 Acrylic acid, triester with pentaerythritol 8 To be fixed
12062 075577-70-7 Acrylic acid, triester with 1,1,1-trimethylolpropane tris(2-hydroxyethyl) ether 8 To be fixed
- 000814-68-6 Acryloyl chloride - To be fixed
- 099561-04-3 Alcohols, tallow - To be fixed
- 000107-05-1 Allyl chloride - To be fixed
- 061790-33-8 Amines, tallow - To be fixed
- 061788-45-2 Amines, tallow, hydrogenated - To be fixed
12730 000060-32-2 6-Aminocaproic acid 8 To be fixed
- 001760-24-3 N-(2-Aminoethyl)--3-(aminopropyl)trimethoxysilane - To be fixed
12771 000111-41-1 N-(2-Aminoethyl)ethanolamine W7 To be fixed
12775 000124-68-5 2-Amino-2-methyl-1-propanol 8 To be fixed
12784 000056-18-8 N-(3-Aminopropyl)-1,3-diaminopropane 8 To be fixed
72

- 003179-76-8 (3-Aminopropyl)diethoxymethylsilane - To be fixed

- 000056-84-8 Aspartic acid - To be fixed
- 000078-67-1 Azobisisobutyronitrile - To be fixed
- 003287-99-8 Benzylamine, hydrochloride - To be fixed
- 000100-44-7 Benzyl chloride - To be fixed
13240 003377-24-0 2,2-Bis(4-aminocyclohexyl)propane 8 To be fixed
13321 000080-04-6 2,2-Bis(4-hydroxycyclohexyl)propane 8 To be fixed
(39630) 000140-95-4 N,N'-Bis(hydroxymethyl)urea 8 To be fixed
13660 000584-03-2 1,2-Butanediol 8 To be fixed
- 000106-88-7 1-Butene oxide - To be fixed
13960 001852-16-0 N-(Butoxymethyl)acrylamide 6A To be fixed
- 000110-65-6 2-Butynediol - To be fixed
- 000079-07-2 Chloroacetamide - To be fixed
(43630) 000059-50-7 p-Chloro-m-cresol 8 To be fixed
- 000088-04-0 4-Chloro-3,5-dimethylphenol - To be fixed
- 000126-83-0 3-Chloro-2-hydroxypropanesulphonic acid, sodium salt - To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
- 007790-94-5 Chlorosulphonic acid - To be fixed
(43920) 015242-96-3 Chromic chloride stearate 9 To be fixed
- 000123-73-9 Crotonaldehyde - To be fixed
14836 014861-06-4 Crotonic acid, vinyl ester 7 To be fixed
14905 000108-93-0 Cyclohexanol 8 To be fixed
- 002873-97-4 Diacetone acrylamide - To be fixed
- 000078-90-0 1,2-Diaminopropane - To be fixed
15340 000109-76-2 1,3-Diaminopropane 8 To be fixed
15414 000096-76-4 2,4-Di-tert-butylphenol 8 To be fixed
15418 000128-39-2 2,6-Di-tert-butylphenol 8 To be fixed
- 010222-01-2 2,2-Dibromo-2-cyanoacetamide - To be fixed
- 000330-54-1 N'-(3,4-Dichlorophenyl)-N,N-dimethylurea - To be fixed
- 000096-23-1 1,3-Dichloro-2-propanol - To be fixed
15735 000111-42-2 Diethanolamine 8 To be fixed
73

- 000109-89-7 Diethylamine - To be fixed

(48370) 000100-37-8 Diethylethanolamine - To be fixed
- 000868-63-3 N,N'-(1,2-Dihydroxyethylene)bisacrylamide - To be fixed
- 003845-76-9 N-(Dimethylaminopropyl)acrylamide - To be fixed
16225 000109-55-7 N,N-Dimethyl-1,3-diaminopropane 8 To be fixed
- 000115-10-6 Dimethyl ether - To be fixed
- 000107-54-0 3,5-Dimethyl-1-hexyn-3-ol - To be fixed
- 046917-07-1 Dimethyl(methacryloyloxyethyl)benzylammonium chloride - To be fixed
16400 003377-92-2 2,2-Dimethylpropionic acid, vinyl ester 7 To be fixed
16420 000123-91-1 Dioxane 6A To be fixed
16510 000138-86-3 Dipentene 8 To be fixed
16685 023235-61-2 Ditrimethylolpropane 8 To be fixed
- 002627-95-4 1,3-Divinyltetramethyldisiloxane - To be fixed
- 058598-42-8 Docosenylsuccinic anhydride - To be fixed
- 000123-01-3 Dodecylbenzene - To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
- 000112-55-0 Dodecylmercaptan - To be fixed
16709 027193-86-8 Dodecylphenol 9 To be fixed
16717 025134-21-8 Endomethylenemethyltetrahydrophthalic anhydride 8 To be fixed
16719 003813-52-3 Endomethylenetetrahydrophthalic acid 8 To be fixed
16720 000826-62-0 Endomethylenetetrahydrophthalic anhydride 8 To be fixed
- 040618-18-6 Epoxysuccinic acid, disodium salt - To be fixed
- 000106-86-5 1,2-Epoxy-4-vinylcyclohexane - To be fixed
- 002956-58-3 N,N'-Ethylenebisacrylamide - To be fixed
- 000094-04-2 2-Ethylhexanoic acid, vinyl ester - To be fixed
- 028106-30-1 Ethylstyrene - To be fixed
17150 000078-27-3 1-Ethynylcyclohexanol 8 To be fixed
17305 000141-02-6 Fumaric acid, bis(2-ethylhexyl) ester 8 To be fixed
17350 000105-75-9 Fumaric acid, dibutyl ester 7 To be fixed
17392 007283-70-7 Fumaric acid, diisopropyl ester 7 To be fixed
74

17476 002459-05-4 Fumaric acid, monoethyl ester 7 To be fixed

(55660) 000111-30-8 Glutaraldehyde 7 To be fixed
- 001830-78-0 Glycerol 1,3-dimethacrylate - To be fixed
- 000123-34-2 Glycerol 1-monoallyl ether - To be fixed
- 000298-12-4 Glyoxylic acid - To be fixed
18320 000629-73-2 1-Hexadecene 8 To be fixed
18400 000592-42-7 1,5-Hexadiene 7 To be fixed
- 004719-04-4 Hexahydro-1,3,5-tris(2-hydroxyethyl)-1,3,5-triazine - To be fixed
- 000107-46-0 Hexamethyldisiloxane - To be fixed
- 015894-70-9 Hexamethylenebis(dicyanodiamide) - To be fixed
- 022527-59-9 Hexamethylenediamine hydrochloride - To be fixed
- 003779-63-3 Hexamethylenediisocyanate cyclic trimer - To be fixed
- 003699-54-5 N-(2-Hydroxyethyl)ethyleneurea - To be fixed
- 003445-11-2 N-(2-Hydroxyethyl)pyrrolidone - To be fixed
18910 000288-32-4 Imidazole 8 To be fixed
18970 000078-83-1 Isobutanol 8 To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
19030 016669-59-3 N-(Isobutoxymethyl)acrylamide 6A To be fixed
- 025265-77-4 Isobutyric acid, monoester with 2,2,4-trimethyl-1,3-pentanediol - To be fixed
- 002210-25-5 N-Isopropylacrylamide - To be fixed
19265 030399-84-9 Isostearic acid 8 To be fixed
19315 000617-52-7 Itaconic acid, dimethyl ester 8 To be fixed
19570 000999-21-3 Maleic acid, diallyl ester 6A To be fixed
19600 000105-76-0 Maleic acid, dibutyl ester 7 To be fixed
19720 001330-76-3 Maleic acid, diisooctyl ester 7 To be fixed
19750 000624-48-6 Maleic acid, dimethyl ester 7 To be fixed
19780 002915-53-9 Maleic acid, dioctyl ester 7 To be fixed
19915 000925-21-3 Maleic acid, monobutyl ester 7 To be fixed
19933 003990-03-2 Maleic acid, monoethyl ester 7 To be fixed
19936 007423-42-9 Maleic acid, mono(2-ethylhexyl) ester 8 To be fixed
19945 003052-50-4 Maleic acid, monomethyl ester 7 To be fixed
75

- 016215-21-7 3-Mercaptopropionic acid, butyl ester - To be fixed

20005 051410-72-1 Methacrylamidopropyltrimethylammonium chloride 6A To be fixed
20320 003179-47-3 Methacrylic acid, decyl ester 7 To be fixed
20380 001189-08-8 Methacrylic acid, diester with 1,3-butanediol 8 To be fixed
- 000109-16-0 Methacrylic acid, diester with triethyleneglycol - To be fixed
20560 000142-90-5 Methacrylic acid, dodecyl ester 7 To be fixed
20935 002495-27-4 Methacrylic acid, hexadecyl ester 7 To be fixed
20940 000142-09-6 Methacrylic acid, hexyl ester 7 To be fixed
- 024599-21-1 Methacrylic acid, 2-hydroxyethyl ester, monophosphate - To be fixed
- 052628-03-2 Methacrylic acid, 2-hydroxyethyl ester, phosphate - To be fixed
20945 004664-49-7 Methacrylic acid, 2-hydroxyisopropyl ester 7 To be fixed
20950 000923-26-2 Methacrylic acid, 2-hydroxypropyl ester 8 To be fixed
20980 007534-94-3 Methacrylic acid, isobornyl ester 8 To be fixed
21205 025736-86-1 Methacrylic acid, monoester with polyethyleneglycol 7 To be fixed
21220 032360-05-7 Methacrylic acid, octadecyl ester 8 To be fixed
- 086261-90-7 Methacrylic acid, 2-(2-oxo-1-imidazolidinyl)ethyl ester - To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
21415 002549-53-3 Methacrylic acid, tetradecyl ester 7 To be fixed
- 000075-75-2 Methanesulphonic acid - To be fixed
- 000625-45-6 Methoxyacetic acid - To be fixed
21580 003644-11-9 N-(Methoxymethyl)acrylamide 6A To be fixed
21610 003644-12-0 N-(Methoxymethyl)methacrylamide 6A To be fixed
21620 000107-98-2 1-Methoxy-2-propanol 8 To be fixed
21630 001187-59-3 N-Methylacrylamide 6A To be fixed
- 000920-46-7 Methacryloyl chloride - To be fixed
- 000109-83-1 N-Methyl-2-aminoethanol - To be fixed
- 029385-43-1 Methylbenzotriazole - To be fixed
21733 000115-19-5 2-Methyl-3-butyn-2-ol 8 To be fixed
- 034066-95-0 1-Methyldiethylenetriamine - To be fixed
21790 000110-26-9 Methylenebisacrylamide 6A To be fixed
- 000096-29-7 Methyl ethyl ketone oxime - To be fixed
76

- 000077-49-6 2-Methyl-2-nitro-1,3-propanediol - To be fixed

22080 000108-11-2 4-Methyl-2-pentanol 8 To be fixed
22240 000622-97-9 p-Methylstyrene 6A To be fixed
- 026591-72-0 1-Methyl-3-vinylimidazolium methyl sulphate - To be fixed
22340 000074-89-5 Monomethylamine W8 To be fixed
22428 051000-52-3 Neodecanoic acid, vinyl ester 7 To be fixed
22435 054423-67-5 Neononanoic acid, vinyl ester 7 To be fixed
22535 025154-52-3 Nonylphenol 9 To be fixed
- 000556-67-2 Octamethylcyclotetrasiloxane - To be fixed
- 067554-50-1 Octylphenol - To be fixed
- 000112-90-3 Oleyl amine - To be fixed
- 003089-19-8 N-[2-(2-Oxo-1-imidazolidinyl)ethyl]methacrylamide - To be fixed
22861 000111-29-5 1,5-Pentanediol 8 To be fixed
- 000090-30-2 N-Phenyl-1-naphthylamine - To be fixed
- 002788-26-3 Phosphonosuccinic acid, tetramethyl ester - To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
(76430) 008002-09-3 Pine oil 8 To be fixed
- 068131-73-7 Polyethylenepolyamines - To be fixed
- 093571-73-4 Polyethylenepolyamines, diethylenetriamine fraction, distillation residues - To be fixed
- 000074-98-6 Propane - To be fixed
Silicic acid, sodium salt, reaction products with chlorotrimethylsilane and
- To be fixed
- 068988-56-7 isopropanol
- 000107-19-7 2-Propyn-1-ol - To be fixed
- 011099-06-2 Silicic acid, tetraethyl ester, polymer - To be fixed
(91520) 005138-18-1 Sulphosuccinic acid 8 To be fixed
- 000077-78-1 Sulphuric acid, dimethyl ester - To be fixed
- 007782-99-2 Sulphurous acid - To be fixed
- 007446-11-9 Sulphur trioxide - To be fixed
25030 016646-44-9 Tetra(allyloxy)ethane 6A To be fixed
25105 000112-57-2 Tetraethylenepentamine 8 To be fixed
- 055566-30-8 Tetrakis(hydroxymethyl)phosphonium sulphate - To be fixed
77

- 064338-16-5 2,2,4,4-Tetramethyl-7-oxa-3,20-diazadispiro[5.1.11.2]heneicosan-21-one - To be fixed

25330 000070-55-3 p-Toluenesulphonamide 7 To be fixed
(93595) 000080-48-8 p-Toluenesulphonic acid, methyl ester 8 To be fixed
25350 004130-08-9 (Triacetoxy)vinylsilane 6A To be fixed
25390 000101-37-1 Triallyl cyanurate 6A To be fixed
25405 001025-15-6 Triallyl isocyanurate 6A To be fixed
(93870) 000071-55-6 1,1,1-Trichloroethane D To be fixed
- 000088-06-2 2,4,6-Trichlorophenol - To be fixed
- 000108-77-0 2,4,6-Trichloro-1,3,5-triazine - To be fixed
- 000075-50-3 Trimethylamine - To be fixed
- 000108-67-8 1,3,5-Trimethylbenzene - To be fixed
- 025620-58-0 Trimethylhexamethylenediamine - To be fixed
25810 015625-89-5 1,1,1-Trimethylolpropane triacrylate 8 To be fixed
- 003901-77-7 2,4,6-Trimethyl-2,4,6-trivinylcyclotrisiloxane - To be fixed
25930 001067-53-4 Tris(2-methoxyethoxy)vinylsilane 6A To be fixed
 ADI/TDI
PM/REF No CAS No NAME SCF-L RESTRICTION
mg/kg bw
25950 001852-04-6 Undecanedioic acid 8 To be fixed
- 000111-81-9 10-Undecenoic acid, methyl ester - To be fixed
- 000593-67-9 Vinylamine - To be fixed
- 002235-00-9 N-Vinylcaprolactam - To be fixed
- 001746-03-8 Vinylphosphonic acid - To be fixed
26215 000100-69-6 2-Vinylpyridine 6A To be fixed
26217 000100-43-6 4-Vinylpyridine 6A To be fixed
78
 TECHNICAL DOCUMENT No. 2

GUIDELINES ON TEST CONDITIONS AND METHODS OF ANALYSIS

FOR PAPER AND BOARD MATERIALS AND ARTICLES
INTENDED TO COME INTO CONTACT WITH FOODSTUFFS
Version 3 -14.11.2007

79
 Table of contents
Page

1. Introduction ....................................................................................................... 81

2. Sampling ........................................................................................................... 81

3. Testing for compliance with QMA restrictions .................................................... 81

4. Testing for compliance with SML restrictions ..................................................... 81

5. Contact conditions differing from the conventional ratio of 1 kg to 6 dm2 ........... 82

6. Speciality papers ............................................................................................... 82

7. Methods of analysis .......................................................................................... 83

8. References ........................................................................................................ 84

Appendix A Analytical methods for testing of papers made from

recycled fibres . 85

80
1. Introduction

The Technical document gives guidance on the conditions and methods of analysis to be
used for testing paper and board intended to come into contact with food. It should be read
in conjunction with the specifications laid down in Resolution ResAP (2002) 1 on paper and
board materials and articles intended to come into contact with foodstuffs.

2. Sampling

Tests pieces from samples should be chosen so that all components are represented at the
same percentage composition as in the original material or article. When an article is being
tested, all auxiliaries used in production of the article should be taken into account, such as
printing inks, lacquers, adhesives etc.

3. Testing for compliance with QMA(1) restrictions

3.1. General rule

Testing for compliance with QMA restrictions (mg/6dm2) should measure the total
concentration of the substance in the paper.

3.2 . QMA restrictions laid down in Table 1 and Table 2 of Resolution ResAP (2002) 1
on paper and board materials and articles intended to come into contact with
foodstuffs

In principle, testing for compliance with the QMA restrictions in Table 1 of Resolution ResAP
(2002) 1 should measure the total concentration of a substance in the paper. The substance
can be measured in situ or by total release of the substance by extraction from the material
or by degradation of the paper matrix.

The tests for compliance with the QMA restriction for cadmium, lead and mercury of Table 1
of Resolution ResAP (2002) 1 which are listed in Section 7 of this document, are based on
aqueous extraction(2) and do not necessarily determine the total concentration of the
substances in the finished material or article. However, these tests are generally recognised
as appropriate to establish compliance.

Testing for compliance with the purity restriction for pentachlorophenol of Table 2 of
Resolution ResAP (2002) 1 can be made using a method based on extraction of the total
amount in the paper.

4. Testing for compliance with SML restrictions

4.1. General rule

In principle, testing for compliance with SML restrictions should be carried out by migration
testing, using the conditions established in Directive 82/711/EEC and amendments, as well
as in Directive 85/572/EEC. However, extraction tests could be used if, on the basis of
scientific evidence, the results obtained using these tests are at least equal to those
obtained by migration testing using the conventional EU test simulants or foodstuffs.

(1)
The numerical value of QMA expressed as mg/6dm 2 of material corresponds to the numerical value of SML
expressed as mg/kg of food or food stimulant.
(2)
Extraction using simulant B (3% aq. acetic acid w/v) should be used for paper intended to come into contact with acidic
foodstuffs.

81
4.2. Migration tests

EU Directive 85/572/EEC as well as EU Directive 82/711/EEC and its amendments

(Directive 93/8/EEC and Directive 97/48/EC) should be used for guidance on the selection of
appropriate simulants and exposure conditions (time and temperature). However for those
foodstuffs for which in Directive 85/572/EEC no simulant is provided (dry foodstuffs),
migration testing should be carried out using modified polyphenylene oxide (MPPO) as a test
medium.

Testing should take into account the worst foreseeable conditions of use for the material.
This will include the type of foodstuff with which the paper comes into contact, and the time
and temperature of contact.

5. Contact conditions differing from the conventional ratio of 1 kg to 6 dm2

For contact conditions where the mass of food to contact area ratio differs from the
conventional ratio of 1 kg food to 6 dm2 of paper, the restriction to be applied (Q) is
calculated as follows:

QMAstd.
Q = x 6 x m
CAnor

Where: Q (quantity of substance in the finished material or article) is the restriction to

be applied taking into account the conditions under normal or worst
foreseeable conditions of use;

QMAstd is the QMA restriction under the conventional conditions of

1 kg to 6 dm2;

m is the mass of food (in kg) under normal or worst foreseeable

conditions of use;

CAnor is the contact area (in dm2) under normal or worst

foreseeable conditions of use.

6. Speciality papers

6.1. Paper for use at high temperature such as baking paper

Migration testing should be carried out using only MPPO as a test medium regardless of the
type of food and using the time and temperature of contact provided in Directive 82/711/EEC
and its amendments.

Testing should take into account possible degradation products formed at elevated
temperatures. When carrying out extraction testing to determine compliance with Resolution
ResAP (2002) 1 the sample should, in principle, be preheated in a closed container,
according to the time and temperature conditions given in Directive 82/711/EEC and its
amendments.

82
6.2. Paper used for filtering large volumes of liquid such as filters for industrial use
and milk filters

6.2.1. Migration tests

Where the total volume to be filtered is from 1 to 10 l/dm2 of paper, before testing, 0.5 l of the
food or food simulant per dm2 should be passed through the test material and discarded. A
further portion, 0.5 l/dm2, of the food or simulant should then be passed through the material
and analysed to obtain the test result.

Where the total volume to be filtered is above 10 l/dm2 of paper, before testing, one litre of
the food or food simulant per dm2 should be passed through the test material and discarded.
A further portion, 1 l/dm2, of the food or simulant should then be passed through the material
and analysed to obtain the test result.

For filtration papers used to filter oils, migration tests should be carried out using olive oil
simulant (or the recognised alternative fatty food simulants or substitute test media) or with
the same type of oil as will be filtered in normal use of the paper.

6.2.2. Extraction tests and tests for QMA

For testing compliance with a QMA restriction, or when using extraction tests to determine
compliance with an SML restriction, the material should be tested directly after the first 0.5
l/dm2 has been passed through the material and discarded.

7. Methods of analysis

The Council of Europe and the EU Commission do not normally issue resolutions or
directives in the field of methods of analysis. The progress in this area is so rapid that any
method may be considered obsolete after a limited number of years. However, there is a
need to provide guidance to analysts who carry out testing to ensure compliance with the
requirements of Resolution ResAP (2002) 1 (e.g. enforcement authorities, industry, food and
food packaging retailers and certification laboratories).

It is recommended that internationally recognised and validated methods of analysis are

applied. For the purpose of this document this includes methods recognised by the following
bodies: CoE, EU, CEN, ISO.

If such a method does not exist currently, an analytical method with appropriate performance
characteristics (accuracy and precision) at the specified limit may be used.

A list of current relevant CEN and ISO standards is given below:

Determination of pentachlorophenol (EN 15320)

Determination of cadmium and lead in aqueous extract (EN 12498)
NB. This method is appropriate for contact with non acidic foodstuffs
Determination of mercury in aqueous extract (EN 12497)
NB. This method is appropriate for contact with non acidic foodstuffs
Preparation of a cold water extract (EN 645)
Preparation of a hot water extract (EN 647)
Sensory analysis. Part 2: Off flavour (taint) (EN 1230:2)
Determination of microbiological properties. Part 1: Total bacteria count (ISO 8784-1)
Determination of formaldehyde in an extract (EN 1541)

83
 Determination of antimicrobial constituents (EN 1104)
Migration into modified polyphenylene oxide (MPPO) (EN 14338)

Analytical methods for testing of papers made from recycled fibres are summarised in
Appendix A.

8. References

Council Directive of 18 October 1982 laying down the basic rules necessary for testing
migration of the constituents of plastic materials and articles intended to come into contact
with foodstuffs (82/711/EEC). Official Journal of the European Communities L297/26,
23.10.82.

Council Directive of 19 December 1985 laying down the list of simulants to be used for
testing migration of constituents of plastic materials and articles intended to come into
contact with foodstuffs (85/572/EEC). Official Journal of the European Communities
L372/14, 31.12.85.

Commission Directive of 29 July 1997 amending for the second time Council Directive
82/711/EEC laying down the basic rules necessary for testing migration of the constituents
of plastic materials and articles intended to come into contact with foodstuffs (97/48/EC).
Official Journal of the European Communities L222/10, 12.8.97.

Council of Europe Resolution AP (96) 4 on maximum and guideline levels and on source-
directed measures aimed at reducing the contamination of food by lead, cadmium and
mercury, adopted by the Committee of Ministers on 2 October 1996.

84
APPENDIX A

Analytical methods for testing of papers made from recycled fibres

The analytical methods listed below have been used for the analysis of papers made from
recycled fibres. A number of these methods are not internationally recognised and/or
validated. Those wishing to use these methods for testing purposes should ensure that they
evaluate the performance of the methods.

Michler's ketone and 4,4'-bis(diethylamino)benzophenone

Determination by GC-MS as described in (1).

Diisopropylnaphthalenes

For the determination in paper the methods described in (2), (3), and (4) are used.

A European standard was developed. (EN 14719).

Partially Hydrogenated Terphenyls

A method is described in (5).

Phthalates

Analysis can be performed by GC/MS after solvent extraction, for details see (6) and (7).

Solvents

The content in residual solvents can be tested by Headspace-GC/MS according to (8).

Azo colourants

For analysis the method provided in (9) can be used. Following this method the azo
colourants are cleaved reductively and the formed amines are determined by HPLC/DAD,
TLC, GC/FID and/or MSD, or by CE/DAD. The aromatic amines freely available in paper
before cleavage of the azo bond must be subtracted from the result after the cleavage.

Primary aromatic amines, suspected to be carcinogenic

For screening, the summation method as described in (10) can be used. If the sum of
primary aromatic amines is above the detection limit it is necessary to determine the amines
listed in the proposal for the EU Directive amending for the 19th time the Council Directive
76/769/EEC specifically.

N.B.: CEN TC 194 is preparing a screening method and a method for the specific
determination of primary aromatic amines in food simulants.

Fluorescent whitening agents

A European standard method is available. (11)

85
Polycyclic aromatic hydrocarbons

N.B.: CEN TC 172 is preparing a GC/MS-method for the determination of polycyclic aromatic
hydrocarbons in paper.

Benzophenone

A method is described in (12).

References

(1) Castle, L., Damant, A.P., Honeybone, C.A., Johns, S.M., Jickells, S.M., Sharman, M.
and Gilbert, J. Migration studies from paper and board food packaging materials. Part
2. Survey for residues of dialkylamino benzophenone UV-cure ink photoinitiators.
Food Additives & Contaminants, (1997), 14:45-52.

(2) Sturaro, A., Parvoli, G., Rella, R., Bardati, S. and Doretti, L. Food contamination by
diisopropylnaphthalenes from cardboard packages. International Journal of Food
Science & Technology, (1994), 29:593-603.

(3) Bebiolka, H. and Dunkel, K. bergang von Di-isopropylnaphthalin aus Karton-

verpackungen auf Lebensmittel. Lebensmittelchemie, (1997), 51:53-61.

(4) Boccacci Mariani, M., Chiacchierini, E. and Gesumundo, C. Potential migration of

diisopropylnaphthalenes from recycled paperboard packaging into dry foods. Food
Additives & Contaminants. (1999), 16:207-213.

(5) Sturaro, A., Parvoli, G., Rella, R. and Doretti, L. Hydrogenated terphenyls
contaminants in recycled paper. Chemosphere, (1995), 30:687-694.

(6) MAFF: Food surveillance information sheet, Number 60 May 1995: Phthalates in
paper and board packaging.
http://www.foodstandards.gov.uk/science/surveillance/maffinfo/

(7) Aurela, B., Kulmala, H. and Soderhjelm, L. Phthalates in paper and board packagings
and their migration into Tenax and sugar. Food Additives & Contaminants (1999),
16:571-577.

(8) prEN 14479 Flexible packaging material - Determination of residual solvents by

dynamic headspace gas chromatography.

(9) Amtliche Sammlung von Analysenverfahren nach 35 LMBG, Methode B 82.02 - 2

"Nachweis der Verwendung verbotener Azofarbstoffe auf gefrbten textilen
Bedarfsgegenstnden".

(10) Amtliche Sammlung von Untersuchungsverfahren nach 35 Lebensmittel- und

Bedarfsgegenstndegesetz, Methode L 00-00-6: Bestimmung von primren
aromatischen Aminen in wssrigen Lebensmittelsimulanzien. (Official Collection of
Methods of Analysis under 35 of the Foods and Other Commodities Act, Method
No. L 00-00.6: Determination of primary aromatic amines in aqueous food simulants).

(11) EN 648 "Paper and board intended to come into contact with food - Determination of
the fastness of fluorescent whitened paper and board".

(12) Johns, S.M., Gramshaw, J.W., Castle, L. and Jickells, S.M. Studies on functional
barriers to migration. 1. Transfer of benzophenone from printed paperboard to
microwaved food. Deutsche Lebensmittel-Rundschau, (1995) 91:69-73.

86
 TECHNICAL DOCUMENT No. 3

GUIDELINES ON PAPER AND BOARD

MATERIALS AND ARTICLES, MADE FROM RECYCLED FIBRES,
INTENDED TO COME INTO CONTACT WITH FOODSTUFFS
Version 2 10.06.2004

87
 Table of contents

Page

1. Introduction ........................................................................................................... 89

2. Good manufacturing practice ................................................................................ 89

3. Recovered paper groups ....................................................................................... 90

4. Foodstuff types ..................................................................................................... 92

5. Current process technologies and their purpose ................................................... 92

6. End-product requirements ..................................................................................... 96

7. Consolidated matrix .............................................................................................. 98

Appendix 1 - Recovered paper process technologies ................................................ 100

88
1. Introduction

The Guidelines on paper and board materials and articles, made from recycled fibres,
intended to come into contact with foodstuffs are for the guidance of the enforcement
authorities, manufacturers and users in order to ensure that the use of the end-product does
not constitute a risk to health in accordance with Article 2 of EU Framework Directive
89/109/EEC.

Paper and board made in part or in full from recycled fibres intended to come into contact
with foodstuffs should comply with the requirements of Resolution ResAP (2002) 1 on paper
and board materials and articles intended to come into contact with foodstuffs and related
technical documents. However such paper and board should be subject to some additional
requirements to ensure their safety in use due to the presence in the feedstock of
constituents of printing inks, adhesives and other substances, e.g. from paper not intended
for food contact.

In order to ensure the safety of the end product the following aspects should be considered
together:

- the source of recovered paper and board;

- the processing technologies applied to remove contaminants;
- the intended end use of the product.

These aspects are basic elements of product safety assurance.

As further elements of product safety assurance, tests should be carried out where
appropriate or advisable as a matter of prudence, to determine the presence of specific
substances in the end-product.

The Guidelines will be amended, as necessary, by the Committee of experts on materials

coming into contact with food, to take account of technological developments in the
processing of recovered paper, improvements in analytical techniques and increased
knowledge of the toxicology of chemical substances.

2. Good manufacturing practice

Good manufacturing practice (GMP) is a fundamental part of quality control and product
safety assurance.

Basic elements of GMP include:

- Availability of production manuals and instructions;

- Compliance with specified quality requirements for raw materials;
- Appropriate storage and handling conditions;
- The application of processes to avoid or remove contamination;
- Specifications for end-product testing;
- Information to ensure traceability and to maintain production records.

Some of these basic elements, which are particularly important for the production of paper
and board made from recycled fibres intended to come into contact with foodstuffs, are
covered in Chapters 3, 5 and 6 of the Guidelines.

Furthermore, see also Technical document No. 4 - CEPI guide for good manufacturing
practice for paper and board for food contact.

89
3. Recovered paper groups

The aim of this chapter is to define the groups of recovered paper and board that can be
used as raw materials in the manufacture of paper and board intended to come into contact
with foodstuffs, as well as those groups of recovered paper and board which cannot be used
as raw materials. These groups are defined in relation to the potential contaminants which
could be present, so as to assist the selection and processing of raw materials as part of
Good manufacturing practice (see Technical document No. 4 - CEPI guide for good
manufacturing practice for paper and board for food contact).

The groups of recovered paper listed below are defined in generic terms for the purpose of
the Guidelines. Where industry use other definitions such as their own specifications or, for
example, the nomenclature in EN 643:2001 some of which are listed below for illustrative
purposes, they should ensure correspondence with the groups below.

3.1. Recovered paper for use as raw materials

The descriptions within each group are given as examples. Where applicable, some grades
listed in EN 643:2001 are indicated.

Group 1

Paper and board manufactured with substances of Technical document No. 1 - List of
substances to be used in the manufacture of paper and board materials and articles
intended to come into contact with foodstuffs.

Unprinted cuttings, shavings, sheets and rolls from food contact paper and board based on
virgin fibres.

Group 2

Paper and board which may be manufactured with substances not mentioned in the List of
substances used in the manufacture of paper and board materials and articles intended to
come into contact with foodstuffs set out in Technical document No. 1 - List of substances to
be used in the manufacture of paper and board materials and articles intended to come into
contact with foodstuffs, unprinted or lightly printed or lightly coloured1.

Unprinted cuttings, shavings, sheets and rolls of printing and writing papers (EN 643:2001-
3.14, 3.15, 3.16, 3.17, 3.18, 3.19);

Lightly printed or coloured cuttings, shavings, sheets and rolls of printing and writing papers
(EN 643:2001- 2.03, 3.01, 3.02, 3.03, 3.04, 3.09);

White writing and printing paper originating from offices (EN 643:2001 - 3.05);

White continuous stationery paper (computer paper) (EN 643:2001 - 3.07);

Unprinted or lightly printed, unused kraft paper (EN 643:2001- 4.07, 4.08);

1
Lightly printed: Papers where the ratio of printed area to unprinted area is very small. Examples of
lightly printed papers are shavings and cuttings, not mixed with misprinted sheets, originating from
printing shops.

Lightly coloured: Papers where only shading dyestuffs have been added during manufacture.(For
example yellow pages in telephone directories are not considered as lightly coloured.)

90
Unprinted or lightly printed, unused packages (EN 643:2001 - 3.12, 3.13, 4.05);

Unused kraft sacks and wrappings.

Group 3

Printed paper and board, corrugated board from supermarkets, paper and board from
households and industry.

Printed or coloured material from printing shops, over-issues etc. (EN 643:2001 - 1.06, 2.02,
2.04, 2.07, 3.08, 3.11);

Unsorted white and coloured writing and printing paper originating from offices;

Boxes and sheets of corrugated board collected from supermarkets (EN 643:2001 - 1.04,
1.05);

Unused boxes and sheets of corrugated board (EN 643:2001 - 4.01);

Printed paper from households, such as newspaper, pamphlets, magazines, catalogues etc.
(EN 643:2001 - 1.11);

Mixed papers and board from households (EN 643:2001 - 1.02, 5.01);

Sheets, boxes and cases of solid and corrugated board and folding boxboard from
households.

3.2. Recovered paper and board not for use as raw materials

Contaminated waste paper and board from hospitals;

Recovered paper and board which has been mixed with garbage and subsequently sorted
out;

Used stained sacks which have contained for example chemicals and foodstuffs;

Covering materials, such as paper used for covering furniture during repair and painting
work;

Batches mainly consisting of carbonless copy paper;

Waste paper from households containing used hygienic paper, such as used kitchen towels,
handkerchiefs and facial tissue;

Old archives from libraries, offices etc., if they contain PCBs.

3.3. Speciality papers

For paper intended for contact with hot, aqueous liquids, such as tea bags, coffee filters and
cooking pouches, or for use at high temperature, such as baking paper, recovered paper of
Groups 2 and 3 should not be used.

91
4. Foodstuff types

Classification of foodstuff types

Foods have been classified into 3 types, taking into account the nature of the food and the
potential for migration in contact with paper and board. The classification laid down in EU
Directive 85/572/EEC should be used to determine the food type for individual foodstuffs
except where Chapter 4 of the Guidelines indicates otherwise.

4.1. Type I - Aqueous and/or fatty foodstuffs

Aqueous foods range from those which are liquid to those which are solid but have a high to
medium water content. Examples of liquid foodstuffs include beverages and water.
Examples of solid foods with a high to medium water content include fresh fish, shellfish,
meat and some cheeses.

Fatty foods range from those which are fully fatty to those which are solid, with a low to
medium moisture content but which have fat on the surface. Example of the former include
animal and vegetable fats. Examples of the latter include pastry products, pizzas,
hamburgers, cheeses and chocolate.

Frozen foods of Type I can be considered to be dry, non-fatty of Type II provided that the
food is not defrosted in contact with paper and board.

4.2. Type II - Dry, non-fatty foodstuffs

Foodstuffs which are dry or with low moisture content and which do not have fat on the
surface. Examples of such foods include sugar, pulses, some bakery wares, salt, tea and
spices.

Type II foodstuffs, e.g. bread, which come into contact with paper and board at temperatures
above room temperature, e.g. in microwave or conventional ovens, should be considered as
Type I foodstuffs.

Frozen foodstuffs of Type II are considered to be foodstuff Type I if they are defrosted in
contact with paper and board.

4.3. Type III - Foodstuffs which are shelled or peeled or washed before consumption

Examples of Type III foodstuffs are fruits, vegetables, nuts and potatoes.

5. Current process technologies and their purpose

This chapter describes current process technologies applied to the raw materials taking into
account the intended use of the end-product. It deals with the processes applied to the
recovered paper at the fibre preparation stage. Paper-making processes are not covered.
The information in this chapter is based on current technical knowledge and should be
reviewed in the light of technological developments. It is recognised that the groups of
recovered paper defined in Chapter 3 of the Guidelines differ in their potential for chemical
and microbiological contamination of foodstuffs depending on the intended use of the end-
product. Recycling process technologies should be adequate to counter this potential for
contamination without imposing unnecessary restrictions. The most efficient processes
should therefore be applied where necessary. The use of chemical reagents, the effects of
washing together with process water treatments, and temperature controls provide some of
the means for achieving chemical decontamination of raw materials.

92
These process technologies, which are summarised in Table 1 of Chapter 5 of the
Guidelines and defined in Appendix 1 below should be seen in the context of the
Consolidated matrix of Chapter 7 of the Guidelines. They link raw materials to the intended
use of the end-product, and to the wider context of Good manufacturing practice (see
Technical document No. 4 - CEPI guide for good manufacturing practice for paper and board
for food contact).

Types of process

5.1. Mechanical cleaning

Repulping, deflaking cleaning and screening are examples of mechanical cleaning and they
are intended to remove physical impurities. However, their impact on chemical
contamination is significant, and is due to the dilution effect since these processes are
carried out at low consistency. Low size components such as fillers and fines (fine fibre
fraction) are released in the process water, and may be removed at subsequent stages. In
addition the level of insoluble contaminants is reduced at this stage. It must be emphasised
that part of the process water, including dissolved and suspended material, is not re-used in
the recycling plant, but is rejected to the wastewater treatment plant.

5.2. Washing

Washing is carried out by successively lowering the consistency by dilution and increasing by
thickening. Some processes are best carried out at high consistency for mechanical and
energy efficiency reasons, such as dispersion. Some screening and cleaning has to take place
prior to this stage at a low consistency, which means that a thickening stage is employed.
Normally, this is carried out by squeezing out excess water, for example in a screw press, belt
press or drum filter. Water-soluble contaminants are dissolved and may be removed if
adequate process water treatments are used.

5.3. De-inking by washing or flotation

De-inking may be carried out either by washing or by flotation. The purpose of de-inking is to
remove ink from printed material. Together with ink particles, some dissolved and colloidal
contaminants are removed. Surface-active agents, such as soaps, are used to help
separation.

5.4. Thermal treatment

This stage is carried out at high consistency. The fibres are subjected to high mechanical
forces together with a steam treatment, generally at temperatures of 60 C, but temperatures
of 140 C may be applied. This process is called hot dispersion and it can be combined with a
chemical treatment by adding chemicals. Thermal treatment reduces the level of chemical and
microbiological contamination.

5.5. Chemical treatment

Chemical treatment may be carried out together with hot dispersion. Generally used chemicals
are hydrogen peroxide, formamidine sulfinic acid (FAS) and sodium hydrosulfite.

The purpose of bleaching is to increase the brightness of white grade papers. Generally
used chemicals are hydrogen peroxide, FAS, sodium hydrosulfite, ozone and oxygen.

Process water treatment aims at controlling microbiological activity. It includes the use of
biocides, slimicides and enzymes.

93
The purpose of process water clarification is to remove suspended solids and colloidal
materials from the water to be re-circulated in order to provide water of a suitable quality to be
re-used back in the process. It avoids recontamination at dilution stages.

Chemical treatments reduce the level of chemical and microbiological contamination.

94
 TABLE 1 - CURRENT PROCESS TECHNOLOGIES AND THEIR PURPOSE

Unit Type of Consistency Equipment / Use of Purpose / Efficiency

operation process (%) chemicals

Mechan. 5 15 Pulper Separation of fibres from each

Repulping Cleaning Use of alkali and/or other, from fillers and other non-
peroxide (in de-inking fibre components
lines) Ink detachment
Mechan. 5 15 Deflaker Disintegration of fibre flakes into
Deflaking Cleaning fibres
Ink detachment
Mechan. 5 15 High density cleaner Removal of coarse, high density
Pre-cleaning Cleaning Rotating drum contaminants (density > 1): sand,
glass, pebble, metal particles
Mechan. 45 Pressurised screens with Removal of coarse, usually
Pre-screening Cleaning holes or slots lightweight, contaminants: plastic
films, textiles, etc., according to
their size and shape
De-inking by De-inking 1 1.5 Flotation cells Removal of ink particles, specks,
flotation Use of surfactants (soaps) low size stickies, etc. (sub-
millimetre size)
De-inking by De-inking, 1 1.5 Washer Removal of ink particles, specks,
washing Washing Use of surfactants (soaps) low size stickies, etc. (sub-
millimetre size)
Removal of specks, low size
Washing Washing 1 1,5 Washer stickies, etc. (sub-millimetre size),
of soluble and colloidal material
Fine cleaning Mechan. 0.7 1 Cleaner Removal of ink particles, residual
Cleaning Hydrocyclone high density impurities
Removal of residual low density
Fine Mechan. 0.7 4 Pressurised screens with impurities according to size and
screening Cleaning slots or holes shape (varnishes, sticky
agglomerates, ink particles, etc.)
Raise consistency, in particular
Thickening Washing 0.7 5 Filter drum prior to hot dispersion or
15 30 Screw press bleaching, removal of fillers,
dissolved material, fines, etc.
Disperser (high speed) Dispersion of visible impurities: ink
Kneader (low speed) particles, specks, hot melt
Hot dispersion Thermal 20 30 Use of direct steam and adhesives, waxes, etc.
treatment possibly peroxide Residual ink detachment
Temp. 60 130C Microbiological decontamination
Reactors, bleaching towers Increase of brightness
Bleaching Chemicals 15 30 Oxidising or reducing Removal of dyestuffs and in some
treatment agents cases optical brighteners
Temp. 60C Microbiological decontamination
Process water Chemical Use of biocides, antislimes Microbiological control of process
treatment treatment water
Decrease of biological oxygen
Clarification of Chemical Coagulation tanks demand (BOD) and chemical
recirculated treatment Microflotation cells oxygen demand (COD)
water Coagulation and removal of
colloidal material and fillers

95
6. End-product requirements

The aim of this chapter is to specify the requirements for the end-product and tests to be
carried out.

Restrictions laid down in Resolution ResAP (2002) 1 and related technical documents apply to
the end-product. Additional restrictions for the end-product are specified in Table 2 of Chapter
6 of the Guidelines. These additional restrictions are for substances which have the potential to
be present in paper made of recycled fibres, and to migrate into foodstuffs at levels which may
pose a risk to health. The list is based on current knowledge of chemicals which are found in or
could migrate from recycled fibres.

Some of the restrictions for particular substances are based on evaluations by recognised
international bodies, e.g. SCF or JECFA. Where restrictions have not yet been established
by a recognised body, the requirements in Table 2 of Chapter 6 of the Guidelines have been
made on grounds of prudence, to ensure that migration into foods is kept as low as
reasonably achievable.

The end-product should be tested in accordance with the procedure specified in the
Guidelines on test conditions and methods of analysis for paper and board materials and
articles intended to come into contact with foodstuffs set out in Technical document No. 2
Guidelines on test conditions and methods of analysis for paper and board materials and
articles intended to come into contact with foodstuffs, in order to ensure compliance with Art.
2 of EU Directive 89/109/EEC.

It is not necessary to carry out specific testing for compliance if there is conclusive evidence,
assuming 100% migration based on the content in the end-product or in the raw materials,
that the migration of the substances is so low that compliance with Art. 2 of EU Directive
89/109/EEC is ensured.

Tests should be carried out for substances with a demonstrated toxic potential whenever
there are grounds to suspect their presence in the end-product.

Chemical or toxicological screening tests for possible unknown toxic substances are desirable.
However, at present the implementation of chemical screening tests for unknown substances
might not be feasible. Furthermore, the knowledge about the applicability of toxicological
screening tests for paper and board is insufficient for the time being although it should be noted
that studies are in progress to establish the validity of these tests for paper and board. The use
of these chemical or toxicological screening tests on paper and board should be evaluated and
should be recommended in the future where necessary, based on new developments and
results in this field.

96
 TABLE 2 - SPECIFIC REQUIREMENTS

Requirements
Substance (Food types I and II unless otherwise specified)

Michlers ketone The migration of this substance should not be detectable in foodstuffs (limit of
detection of 0.01 mg/kg foodstuff)
Testing required for Food Type I only

4,4-Bis (diethylamino) The migration of this substance should not be detectable when measured in
benzophenone (DEAB) foodstuffs (limit of detection of 0.01 mg/kg foodstuff)
Testing required for Food Type I only

Diisopropylnaphthalenes (DIPNs) Levels in paper and board should be kept as low as reasonably achievable, to
minimise migration into food

Partially hydrogenated Levels in paper and board should be kept as low as reasonably achievable, to
terphenyls (HTTP) minimise migration into food

See EU Directive 90/128/EEC or Synoptic document (convert TDI to SML

Phthalates using convention TDI x 60=SML and convert SML to QM using the formula
specified in the Test conditions and methods of analysis for paper and board
materials and articles intended to come into contact with foodstuffs set out in
Technical document No. 2)

The volatility of most solvents ensures that they are not present in the finished
Solvents product. `However, industry should take the necessary steps to ensure that
residual solvents are reduced to the lowest possible levels in the finished
product, so that migration into food does not pose a risk to health

Soluble azo colourants which may cleave to form aromatic amines listed in
th
Azo colourants the proposal for the EU Directive, amending for the 19 time the Council
Directive 76/769/EEC
The aromatic amines should not be detectable when measured in paper (limit
of detection of 0.1 mg/kg paper) Testing required for Food Type I only

Fluorescent whitening agents The migration of these substances should not be detectable when measured
1
(FWA) in foodstuffs
Testing required for Food type I only

Primary aromatic amines, These substances should not be detectable when measured in paper (limit of
suspected to be carcino- detection of 0.1 mg/kg paper)
2
genic Testing required for Food Type I only

Polycyclic aromatic The migration of these substances should not be detectable when measured
hydrocarbons (PAH) in foodstuffs (limit of detection of 0.01 mg/kg foodstuff)

2
Benzophenone Specific migration limit of 0.1 mg/dm of paper

1
Tests should be carried out according to EN 648
2 th
See: proposal for the EU Directive, amending for the 19 time the Council Directive
76/769/EEC, opinions expressed by SCF, IARC and other competent bodies

97
7. Consolidated matrix

Tests on end-products are necessary where there are actual or potential risks to health.
These risks depend on the nature of the recovered paper, the effectiveness and purpose of
recycling treatments and the nature of the contact with foodstuffs for the end-product. All of
these elements are combined with the requirements in Chapter 6 of the Guidelines.

The process technologies listed in Table 3 of Chapter 7 hereafter provide flexibility to take
account of mill-specific circumstances. The purpose of these processes is to reduce or
eliminate the presence of contaminants in the finished product and to fulfil the requirements
set in Chapter 6 of the Guidelines. Other processes or combination of processes may be
used in order to fulfil these requirements. It is the responsibility of industry to demonstrate
through Good manufacturing practice (see Technical Document No. 4 CEPI Guide for
good manufacturing practice for paper and board for food contact ) that the end-product
meets the requirements of Art. 2 of Council Directive 89/109/EEC.

98
 TABLE 3 - CONSOLIDATED MATRIX
PART I
The matrix should be read in conjunction with the rest of the Guidelines
Food type Recovered paper group Process technologies Additional end-product
(Chapter 4) (Chapter 3) (Chapter 5) requirements
(other processes or (Chapter 6)
combinations of (tests should be carried out
processes may be used for other toxic substances
provided that the end- whenever there are grounds to
product fulfils the suspect their
requirements of Chapter 6) presence in the end-
product)

Group 1: Paper and board Mechanical cleaning The requirements of Table 2 of

manufactured with substances the Guidelines do not apply
Food type I listed in Technical document
Aqueous and/or fatty No. 1
foodstuffs (including
defrosted)

Group 2: Paper and board Mechanical cleaning Michlers ketone, DEAB, DIPNs,
manufactured with substances not Washing HTTP, Phthalates, Solvents, Azo
listed in Technical document No. 1, Chemical treatment, colourants, FWAs, Aromatic
unprinted or lightly printed or lightly unless it is not necessary amines, Polycyclic aromatic
coloured Thermal treatment, hydro-carbons, Benzophenone
unless it is not necessary

Group 1: Paper and board The requirements of Table 2 of

manufactured with substances the Guidelines do not apply
of the List of substances used
in the manufacture of paper and
board materials and articles
intended to come into contact
with foodstuffs (Technical
document No. 1)

Food type II Group 2: Paper and Board which Mechanical cleaning DIPNs, HTTP, Phthalates,
Dry, non-fatty may be manufactured with Washing Solvents, Polycyclic aromatic
foodstuffs, including substances not listed in Technical Thermal treatment, hydrocarbons, Benzophenone
frozen document No. 1, unprinted or lightly unless it is not necessary
printed or lightly coloured

Group 3: Printed paper and board, Mechanical cleaning DIPNs, HTTP, Phthalates,
corrugated board from Washing Solvents, Polycyclic aromatic
supermarkets and paper and board Chemical treatment, unless it hydrocarbons, Benzophenone
from households and industry is not necessary Thermal
treatment, unless it is not
necessary De-inking,
unless it is not necessary

Group 1: Paper and board Mechanical cleaning The requirements of Table 2 of

manufactured with substances the Guidelines do not apply
Food type III Listed in Technical document No. 1
Foodstuffs which are
shelled, peeled or
washed Group 2: Paper and Board which Mechanical cleaning The requirements of Table 2 of
may be manufactured with the Guidelines do not apply
substances not listed in Technical
document No. 1, unprinted or lightly
printed or lightly coloured

Group 3: Printed paper and board, Mechanical cleaning The requirements of Table 2 of
corrugated board from Washing the Guidelines do not apply
supermarkets and paper and board
from households and industry

99
 APPENDIX 1

Recovered paper process technologies

1.1. Repulping

This is always the first step. During pulping, fibres are separated and some additives added
to the paper during the printing and converting process are separated from the fibres.

Various kinds of devices can be used : low, medium or high consistency pulpers and drums
are proposed by machinery suppliers.

The choice of the type of pulper has to be made by considering various parameters including
the efficiency of defiberizing and energy consumption but mainly with respect to:

- efficient ink detachment when de-inking is to be carried out. Chemicals (e.g. caustic soda,
sodium silicate and soap) are used in the pulping stage in order to improve ink release from
the fibres. Bleaching chemicals (such as hydrogen peroxide) can also be used in this stage;

- minimising the breaking-up of contraries, which could reduce their removal efficiency.

1.2. Removal of contraries

The removal of contraries is based on their physico-chemical properties, which differ from
those of cellulosic fibres :

- differences in size : particles smaller than fibres can be removed by washing and
contaminants larger than fibres can be removed by screening (Fig. 1 and 3);

- differences in density : particles having a density other than 1 can be removed by

centrifugal cleaning. Some cleaners are designed to remove high density (>1);
contaminants and others to remove lightweight contaminants (density < 1) (Fig 2);

- differences in surface properties : flotation can remove hydrophobic particles,

additives (collectors) are generally used to improve the flotation efficiency (Fig 4).

In order to ensure good cleaning efficiency, size, shape and density must be considered;
flotation efficiency mainly depends on surface properties.

100
Figure 1: Principle of screening

101
Figure 2: Principle of cleaning

102
Washing can remove fillers and finely divided ink particles, as well as colloidal materials
dispersed in water. Very efficient cleaning is obtained. The drawback is the use of important
volumes of water, which need a suitable treatment, and a significant loss of fibrous and non-
fibrous material. The losses are removed as sludge by the water treatment.

Figure 3 : Principle of washing

Flotation can remove ink (oil-based ink with hydrophobic characteristics), varnishes and
various adhesive particles. Flotation efficiency also depends on particle size, which has to be
severely controlled at the pulping stage.

Cleaning (heavy contaminants) can remove metals, sand, glass, and some varnish particles.
This technique is also used to remove toner ink after agglomeration with appropriate
chemicals.

Cleaning (lightweight contaminants) can remove hot melt adhesives and various plastic
particles.

Screening can remove large contaminants including plastic films, shives, wet strength
papers. Hole screens are efficient with flat contraries, such as varnish particles ; they are
followed by slot screens which remove granular particles. The slot width is usually 150 m.
Screens with 80 m wide slots are currently being developed.

103
Process water treatments are implemented in order to remove fillers and inks from washing
waters and, in some cases, colloids in thickening water. The most common technique involves
microflotation. Additional treatments with biocides are used to control microbial growth in the
circuits. This is also applicable to water on the paper machine.

1.3. De-inking by flotation

De-inking lines are made up of a combination of the various techniques. The number of stages
in the process depends on the grade of the furnish and the quality requirement of the de-inked
pulp to be produced.

Recovered papers are defiberised in a medium consistency pulper or a drum pulper (15 to
18% consistency). After dilution, coarse screening removes large contraries such as plastic
films and wet-strength papers. High density cleaning removes heavy contraries such as
staples and sand.

Hole and slot screening are performed at medium consistency (up to 4 %). Then, the pulp is
diluted down to between 1 and 1.4 % consistency and submitted to flotation. Cleaning stages
(heavy and lightweight) take place after flotation, generally after a complementary dilution
(down to 0.7 %). A fine slot screening stage is generally implemented after cleaning. Then the
pulp is thickened on a disk filter. The white water is treated and re-used for dilution in the
various stages of the process. After the filter, the pulp is stored or diluted with water from the
paper machine.

After the thickening stage on the filter, a screw press is used to increase the consistency up
to 30 %, and the pulp may be submitted for hot dispersing and peroxide bleaching.

Post-de-inking (a second de-inking stage, using the same techniques as in the first stage)
performed after hot dispersing and bleaching is carried out in some mills, as an efficient way
to improve brightness and cleanliness.

104
 Figure 4: Principle of de-inking by flotation

1.4. Hot-dispersion

This technology, which is not concerned with contraries removal, can also be used in
recovered fibres processing lines. Hot dispersing with low-speed kneaders or high-speed
dispergers can be used to disperse residual contaminants such as hot-melt adhesives or
specks from varnish particles and toner inks. Some contaminants such as adhesive particles
from labels or tapes show little dispersion ability.

Hot dispersion is an efficient treatment for the detachment of residual ink particles in the
case of processes involving two or more de-inking loops[1].

105
1.5. Bleaching

So-called upgrading treatments can be applied to the pulp, whether de-inked or not.
Brightness is often an important concern and bleaching treatments can be applied to the
reprocessed pulp. Hydrogen peroxide (oxidative) bleaching and sodium hydrosulfite (or FAS)
(reducing) bleaching are the most common treatments used for recovered paper bleaching[2].
Bleaching restores the initial brightness of cellulosic fibres by destroying chromophores[3].
This chemical action may also remove undesired chemical substances and micro-
organisms. Bleaching is in certain cases aimed at colour stripping or destruction of optical
brightening agents[4]. Visual uniformity of the pulp (so-called cleanliness) is also an important
quality. As described previously, this can be improved by hot dispersing.

1.6. Other upgrading treatments

1.6.1. Oxygen treatment

This treatment is carried out in a gaseous oxygen environment, at a high temperature and
under pressure, with metal chelating agents.

1.6.2. Ozone treatment

Ozone is produced by circulating pure oxygen gas between electrodes at a high voltage. It is
a highly reactive gas, which destroys chromophores and micro-organisms. Under certain
conditions, colourants and fluorescent whitening agents may be removed[5].

1.7. Clarification of recirculated water

Process waters are always re-used to a certain extent. The trend is towards more and more
closed systems. The drawback is an increased concentration of unwanted substances:
dissolved organic and inorganic substances (carbohydrates such as starch and
hemicelluloses, salts, colloids etc.), suspended solids (fines, fibres, filler and ink particles
etc). Increased values of chemical and biological oxygen demand (resp. COD and BOD),
suspended solids and microbiological counts are recorded.

Dissolved air flotation systems are used for the removal of suspended solids. Their efficiency
is poor towards colloids (adhesives or polymeric additives arising from recovered papers). A
chemical destabilisation using strongly cationic polyelectrolytes will cause coagulation of the
colloids, which then may be partially removed in the microflotation cells[6].

1.8. Process water treatment

Microbial growth is controlled by selected biocides. The aim of so-called anti-slime

treatments is to avoid the development of scale (aggregates of microbial colonies) or
catalase, an enzyme which is produced by most aerobic micro-organisms for fighting
peroxides and free radical metabolites.

The presence of catalase results in hydrogen peroxide decomposition and low brightness
gain at the bleaching stage [7]. An "absolute" microbiological cleanliness of process waters is
unnecessary. A critical control point approach shows that most germs which are present in
process waters are destroyed at further stages of the process.

106
References
[1]
Galland, G., "Overview of de-inking technology", Centre Technique du Papier, Document
No. 1706, 1995
[2]
Carr, B., Galland, G., Vernac. And Suty, H., The effect of hydrogen peroxide bleaching
on ink detachment during pulping and kneading, TAPPI Recycling Symposium, New
Orleans, (Feb. 20-23 1995)
[3]
Galland, G. Vernac, Y., Dubreuil, M. and Bourson, L. Progress in Bleaching Recovered
Paper Pulps, Progress in Paper Recycling, 2(1): 20-30 (Nov. 1992)
[4]
Lachenal D Bleaching of secondary fibres basic principles, Progress in Paper
Recycling, Vol 4, No. 1, 37-43, (Nov. 1994)
[5]
Kogan J. And Muguet M., Ozone bleaching of de-inked pulp, TAPPI Recycling
Symposium, Boston, Proceedings: 237-244, (May 15-18, 1994)
[6]
Carr B., Brun, J., Galland, G., The incidence of the destabilisation of the pulp on the
deposition of secondary stickies, 3rd Research Forum on Recycling, Vancouver, Canada
(20-22 Nov. 1995)
[7]
Galland, G., Bernard, E. and Vernac, Y., (1989): Recent progress in de-inked pulp
bleaching, Pira, Paper & Board Division Conference, Gatwick, Recent developments in
wastepaper progressing and use: paper 19 (28 Feb-2 March 1989) and Paper Technology
30 (12): 28-33 (Dec 1989).

107
108
 TECHNICAL DOCUMENT No. 4

CEPI GUIDE FOR GOOD MANUFACTURING PRACTICE

FOR PAPER AND BOARD FOR FOOD CONTACT
(prepared by CEPI - 19.12.2002)

109
 Table of contents
Page

SECTION I - Scope, general principles, particular aspects

1. Scope and field of application ......................................................................... 111

2. General aspects and principles ....................................................................... 111
3. Particular aspects ............................................................................................ 112

SECTION II - Hazard analysis approach

1. Inventory of hazards, suggested means of prevention .................................... 114

2. Manufacturing stages for paper products ........................................................ 114

SECTION III - Explanatory note - the paper-making process and glossary of terms

1. Introduction ..................................................................................................... 120

2. The manufacturing chain ................................................................................. 120
3. Paper manufacture .......................................................................................... 120
4. Glossary of terms ............................................................................................ 123

110
SECTION I SCOPE, GENERAL PRINCIPLES, PARTICULAR ASPECTS

1. Scope and field of application

This Good Manufacturing Practice (GMP) is a technical document containing

recommendations for the guidance of paper and board manufacturers. The recommendations
apply to the entire production process of paper and board and cover all fibrous compositions,
virgin and/or recycled fibres. It also applies to all other activities which normally take place at
the paper or board mill including coating, calendering, slitting, sheeting and other mill-based
finishing operations. It does not cover converting operations such as plastic coating,
corrugating, lamination and so on. It applies to paper and board as defined by the resolution.

Existing product liability legislation should be considered in order to make sure that due
responsibility is taken by paper and board manufacturers for all manufacturing factors as
they apply to the product end use. It will be the care of paper and board manufacturers to
provide users with appropriate product information.

It shall be the responsibility of the users of the paper and board to inform the manufacturers
of intended end use.

The recommendations offer organisational and practical advice on the management of key
factors affecting product quality and fitness for purpose, especially safety with respect to
food contact. They cover all the production stages from the raw materials order
(procurement) and supply to the point where the product is dispatched from the paper
manufacturer.

A paper or paperboard material, which the customer has ordered, is thus manufactured
according to an agreed quality standard which includes all requirements existing in relevant
Directives or regulations or legislation which is applicable for food contact paper and board.

2. General aspects and principles

GMP is based on a quality management system, such as the ISO 9000 series of standards
or another, equivalent, recognised scheme and on the relevant principles of a recognised
hazard analysis system, such as HACCP (Hazard Analysis Critical Control Point, see
Section II, below). These systems are related one to each other since they have the same
principles.

For each stage of production, including the receipt of an order, the procurement of raw
materials, the different steps of processing, manufacturing and testing, finishing and shipping
of the product, a total control has to cover, for example:

manuals;
production instruction documents;
specifications for testing;
handling, storage, packaging, preservation, product identification and
delivery;
personal training and commitment, internal auditing;
production and quality records.

A high level of housekeeping, in terms of appropriate level of cleanliness and order, has to
be maintained throughout the whole process.

111
3. Particular aspects

Among the principles of the GMP, the following have to be highlighted:

3.1. Management responsibility

The management has to make a strong commitment to the quality policy and assure that
appropriate responsibility and authority is given, understood and applied at each level of the
organisation

3.2. Personnel training

All personnel should be made aware of their duties and responsibilities concerning the
requirements of the current legislation and of this code of GMP. Their training should be
performed and assessed in a suitable manner. New employees will be made aware of food
contact manufacturing requirements as part of their induction process. Records of
assessments and training received will be maintained.

3.3. Quality system

A quality system has to be installed and maintained in order to assure product conformity to
the specified requirements. Procedures have to be implemented to avoid misunderstanding
when producing the order.

3.4. Raw materials (pulps and non-fibrous components)

A system has to be implemented to ensure that only raw materials in conformity with the
needs of the end product are purchased. Non-fibrous constituents shall be selected
according to Technical document No 1 List of substances used in the manufacture of paper
and board materials and articles intended to come into contact with foodstuffs.

Pulps shall comply with the resolution and, where applicable, with the guidelines on recycled
fibres.

Only qualified suppliers are traded with.

Qualification may be either:

a) by certification to ISO 9000 (or another recognised system).

b) by the confidence, consistency and reliability established with a supplier due to

the existence of a long-term business relationship backed up by continuing
quality assurance tests on the raw material.

All materials from a new supplier or of a new grade must be assessed for suitability for
conversion to the final product. If the results are satisfactory, the material is accepted and
can be ordered in the future against an agreed specification.

All incoming raw materials should be clearly identified and stored only in specially
designated areas. Appropriate cleanliness and hygiene are to be maintained in the raw
materials storage areas.

Control upon reception of raw materials is implemented taking into account also the extent of
control carried out by the suppliers, and the fact that a registered proof of raw material
compliance may be provided upon delivery.

112
3.5. Process control

The process has to be clearly defined and planned; it has to be demonstrated that the
process runs continuously under controlled conditions. Great importance must be given to
the control of the process parameters due to the complexity of paper and board technology,
particularly to avoid and remove possible contamination in order to fulfil the end product
requirements.

Each mill/producer has to identify and keep under control in its own process the critical
control points related to the hazard analysis system (see below) and food contact
requirements. The microbiological load within the mill should be monitored but testing should
be performed only where indicated by the hazard analysis (see below).

3.6. Handling, storage, packaging preservation and delivery

These aspects of the products have to be maintained under control.

It is particularly important that items in stock are well identified and can only be dispatched for
an end use that is permitted within the Directives, regulations, and legislation for food contact.

Appropriate cleanliness and hygiene are maintained in the storage areas.

A clear procedure needs to be developed to ensure dispatch of products that meet the
agreed quality standards.

3.7. Traceability

An accurate system to enable tracking through the production process from raw materials
through to final customer order has to be implemented.

3.8. Labelling

All finished products must be labelled so that production history, including details of raw
materials, manufacturing dates, etc. may be traced.

3.9. Testing

Testing and inspection procedures have to be defined, to verify the compliance of the final
product with the agreed quality standards and with the Resolution and Guidelines.

3.10. Quality records

The results have to be recorded and filed. Procedures for quality recording have to be defined
in order to guarantee the correct identification, collection, filing, and distribution of the quality
reports.

3.11. Testing methods

When available, standardised testing methods are preferred (e.g. CEN, ISO, etc.).

3.12. Calibration procedures

Inspection, measuring and test equipment must be regularly maintained and calibrated;
records of these activities should be kept.

113
3.13. Auditing

Procedures should be defined to verify the correct performance of the quality system. These
will vary according to the chosen quality scheme.

SECTION II - HAZARD ANALYSIS APPROACH

1. Inventory of hazards, suggested means of prevention

The manufacturing stages of reeled and sheeted articles intended to come into contact with
foodstuff are listed, from raw materials to shipping.

The method implemented for the present Guide consists of listing the hazards related to each
manufacturing stage using the principles contained in the HACCP method.

For each manufacturing stage, Tables 1 to 5 indicate which hazards may be encountered
and the means of prevention.

Possible additional hazards related to specific processes, plants or products have to be

inserted directly by each mill.

In Tables 1 to 5, hazards are defined in conformity with the definition given in the note below.

Note:

The HACCP method, as used in food manufacturing and processing, is described in the
revised draft Guidelines indicated in Annex II of the document referenced ALINORM 97/13A
Revised draft Guidelines for the application of hazards, Analysis and Critical Control Point
(HACCP) and system, document which was elaborated by a commission from the
international authority Codex Alimentarius. This document gives the following definition of
the word hazard: A biological, chemical or physical agent in, or condition of, food with the
potential to cause an adverse health effect . The analysis of hazards through the HACCP
method is a procedure consisting of collecting and estimating the information relative to the
hazards and to the conditions leading to their presence, in order to identify which hazards
and conditions are significant regarding food safety, so that they may be submitted to the
HACCP plan mentioned in the standard.

2. Manufacturing stages for paper products

Raw materials
- selection prior to purchase
- transport (delivery to factory)
- reception
- storage
- handling
Fibre preparation process technologies
- de-flaking, de-inking, hot dispersion, etc.
Preparation and introduction of additives
Refining, cleaning, diluting, sheet formation
Drying
Surface treatments
Winding and finishing (calendering, cutting)
Control of finished product
Labelling
Storage of finished products
Shipping

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 TABLE 1

STAGES POSSIBLE HAZARDS SUGGESTED MEANS OF

PREVENTION

FIBROUS RAW
MATERIALS
Contamination from a chemical Reference to Technical document No 1
a) Selection prior to List of substances used in the
and/or microbiological source, due to
purchase the use of raw materials whose manufacture of paper and board materials
safety has not been determined. and articles intended to come into contact
with foodstuffs

Contamination from a chemical Reference to the specifications of both

b) Transport and/or microbiological source, linked carrier and supplier.
with absence of cleanliness (truck,
(delivery to factory) etc.).

Contamination from a chemical Separate areas (where relevant),

c) Reception, storage, and/or microbiological source at the compliance with procedures (quality
handling moment of storage, as a assurance).
consequence of mixing up grades
suitable for food-contact with
unsuitable ones.

115
 TABLE 2

STAGES POSSIBLE HAZARDS SUGGESTED MEANS OF

PREVENTION

NON-FIBROUS Contamination from a chemical Reference to Annex II of the resolution

RAW MATERIALS source, due to the use of raw
materials whose safety has not been
a) Selection prior to determined.
purchase

Contamination from a chemical Reference to the specifications of both

b) Transport and/or microbiological source, linked carrier and supplier.
with absence of cleanliness (truck,
(delivery to factory) tank, etc.).

Labelling error leading to the Indication upon order form about the
introduction of incorrect material. products technical reference.
Definition of requirements upon
ordering.

c) Reception, storage,
handling Contamination from a Appropriate premises. Maintenance of
microbiological source, linked with cleanliness of premises (appropriate
absence of cleanliness. cleaning, rodent control, etc.).

Usage error and contamination from Separate areas (where relevant),

a chemical and/or microbiological compliance with procedures (quality
source, linked with cross assurance), storage duration and
contamination in case of bulk conditions (observance of expiry dates
storage. for use).

116
 TABLE 3

STAGES POSSIBLE HAZARDS SUGGESTED MEANS OF

PREVENTION

Error about raw materials which

may lead to the introduction of
inadequate raw materials into the Manufacturing specifications
pulper.

RE-PULPING AND
OTHER PROCESS Contamination of the pulp from Maintenance of cleanliness of premises (rodent control,
TECHNOLOGIES micro-organisms brought by pests. etc.).

Contamination from a chemical Manufacturing specifications, grade shift procedure.

source, linked with production shift
(from non-food to food products)

Inadequacy of physical
characteristics and/or possible
contamination from a chemical
source, linked with concentration Procedures.
PREPARATION error or overdose of hazardous
Records.
products.
AND
INTRODUCTION
OF ADDITIVES Contamination from micro- Compliance with procedures. Cleaning of preparation
organisms as a consequence of chests. Storage conditions (e.g. temperature).
microbiological growth of a Preventive treatment with biocides.
preparation (e.g. amylaceous
glues).

117
 TABLE 4

SUGGESTED MEANS OF
STAGES POSSIBLE HAZARDS
PREVENTION
Contamination from a Cleaning procedures.
REFINING, microbiological source, linked with
absence of cleanliness (chests, Underwire water treatment
CLEANING, circuits).
DILUTING, SHEET Contamination from a chemical Where cleaning agent is not on positive list,
FORMATION source, from cleaning agents of segregation of cleaning water from other parts
clothing. of machine is needed

Inadequacy of physical Compliance with procedures.

characteristics and/or possible
contamination from chemical
components as a consequence of
a quantity of deposit possibly out of
regulatory tolerance, or out of
SURFACE specification.
TREATMENT

Contamination from micro- Compliance with procedures. Cleaning of

organisms, linked with preparation chests. Storage conditions (e.g.
microbiological growth of a temperature). Preventive treatment with
preparation. biocides

Soiling due to condensation or to

premises dust fallout onto the reel.
WINDING AND
FINISHING Appropriate maintenance of premises.

(FOR REELS)
PALETTISATI0N Contamination from a chemical
and/or microbiological source due
(FOR SHEETS) to the lack of cleanliness of pallets
or inappropriate treatment of the
wood

WRAPPING AND Contamination (toxicological and Appropriate maintenance and cleanliness of

/or organoleptic) from a chemical premises.
PACKAGING and/or microbiological source due
to the lack of cleanliness or lack of Selection of an appropriate packaging
integrity or from packaging material.
materials.

Contamination from a chemical Restricted stored amount of hazardous

source, linked with leakage or cleaning products, or of their residues in
residues from cleaning agents. production areas.
PRODUCTION AREAS
Compliance with procedures.
Contamination from a Cleaning and sanitation (UV insect control
microbiological source linked with lamps and rodent control)
humidity, temperature, and
absence of cleanliness of premises
(undesirable animals and insects).

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 TABLE 5

SUGGESTED MEANS OF
STAGES POSSIBLE HAZARDS
PREVENTION
Inadequacy of physical characteristics Compliance with procedures, process
and/or chemical characteristics possibly control, down-grading and identification
VERIFICATION OF out of the regulatory tolerance. of products which are out of
specification, records.
FINISHED PRODUCTS
Clear and precise identification of
samples for laboratory analysis.

Error of identification of paper or batch Compliance with procedures.

mix-up leading to the use of a paper
LABELLING unsuitable to the required utilisation.

Degradation of the physical Implementation of appropriate

characteristics of paper due to bad conditioning.
storage conditions (humidity,
STORAGE OF temperature) or to excessive storage Compliance with procedures.
duration. Preventive maintenance programme.
FINISHED PRODUCTS
Maintenance of cleanliness of premises
(appropriate cleaning, rodent control).
Contamination from a biological source Compliance with procedures.
such as animals, insects or micro-
organisms, linked with absence of Maintenance of cleanliness of premises
cleanliness within storage areas. (appropriate cleaning, rodent control).

Paper identification error, batch mix-up,

bad condition of loading and of means
of transport, leading to using a paper
unsuitable for the required utilisation.

Implementation of specifications
regarding transport.
Compliance with procedures.
Contamination from a microbiological
source, linked with bad condition and
absence of cleanliness of means of
SHIPPING transport.

Contamination from a chemical source Implementation of specifications

through polluting products from previous regarding transport.
transport.
Requirement for non transportation of
chemicals and odorous products in the
vehicles used.
Compliance with procedures.

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SECTION III - EXPLANATORY NOTE - THE PAPER-MAKING PROCESS AND
GLOSSARY OF TERMS

1. Introduction

This note is designed to accompany the Good Manufacturing Practice written for paper and
board for food contact. It contains a brief description and schematic diagram of the paper-
making process (Figure 2) together with a glossary of terms (Table 6) used in the GMP.

2. The manufacturing chain

The following diagram shows a simplified form of the manufacturing chain from forest to
foodstuff.

forestry and
pulping operations
paper mill conversion,
operations printing, etc
fibre recovery
operations
area covered packaging
by core GMP application
foodstuffs

customer

This shows clearly that the Good Manufacturing Practice covers only a restricted portion of the
manufacturing chain. For the purposes of this document, this is referred to as paper mill
operations and is now described in more detail and illustrated in the schematic diagram
shown later. It is important to note that certain paper products are converted within the paper
mill and then sold direct to retail outlets. These will be subject to special extensions to the
GMP.

3. Paper manufacture (terms in italics are found in the glossary)

3.1 Raw Materials

Paper and board is manufactured mainly from pulp which is derived from wood using a
variety of mechanical and chemical processes and recovered paper. The mixture used
depends upon end use and ranges from 100% virgin pulp through to pulp made from 100%
recovered paper. There are speciality areas which also use synthetic fibres, cotton, etc. Pulp
is supplied direct from forestry and pulping operations. It is delivered to the paper mill in a
dry state in stand-alone mills or in a wet state in mills which are integrated with pulp
manufacture. Recovered paper comes from merchants who use collection systems. It may
be subject to those treatments designed for recovered papers before being passed to the
paper machine. These could include: special pulping, de-inking, bleaching, hot dispersion,
washing, oxygen treatment, ozone treatment and enzymatic treatment.

120
Whatever the source, the pulp is passed to a re-pulping unit where it is mixed with up to 100
times its weight of water and subjected to violent agitation intended to produce a suspension
of individual fibres in water. At this, and subsequent stages, auxiliary chemicals, additives
and fillers may be added. The auxiliary chemicals and additives are usually combined with
the fibrous raw materials at levels below 1% - 2%. Typical materials include sizing agents to
bond the sheet together, pH control agents, de-watering aids, etc. Fillers usually consist of
clay, calcium carbonate or titanium dioxide and are added to modify the optical properties of
the paper and board or as a fibre substitute.

3.2 Paper machine

The fibrous suspension or stock is pumped, via storage chests, various types of cleaning
equipment and refiners, to the paper machine. Here, yet further water is added to produce a
fibre suspension of as little as 1 to 10 parts fibre to 1000 parts water and the resulting
mixture is passed into a head-box which squirts it through a thin slit across the full machine
width (typically 2 - 6 m) on to a moving woven wire mesh. The water is then removed by a
mixture of gravity and suction in a process known as sheet formation where the cellulose
fibres start to consolidate into a thin mat which is almost recognisable as paper.

This web is then lifted from the wire mesh and squeezed between a series of presses where
its water content is lowered to nearly 50%. It then passes around a series of cast-iron
cylinders, heated to temperatures in excess of 130C, where drying and microbiological
decontamination takes place. It is then wound into a full machine width reel at a water
content of 5% to 8%. Some papers may also undergo surface treatments e.g. sizing, grease-
proofing, etc. before the reeling process. Throughout its passage from the wire mesh to the
reeling operation, the paper web is supported on various types of machine clothing moving
at the same speed.

Samples of paper removed from each machine reel are the subject of quality control testing
and verification against the required specifications as part of the quality system.

3.3 Finishing, storage and despatch

Full machine width reels are passed into a separate area where they are subjected to further
operations. These may be either simple operations where the reel is slit into a number of
more narrow reels or cut into sheets. In some cases, intermediate processes may be
performed such as wrapping, coating or calendering.

The products of the above operations are labelled and placed in a despatch area to await
transport. Again, samples may be taken for quality control purposes and the results of earlier
tests will be checked against the inventory to ensure that only approved material goes forward.

121
 wood pulp water
slushing, screening &
cleaning operations auxiliary
recovered chemicals,
paper recovered additives,
paper
storage chests fillers
process
technologies

water
stock
preparation cleaning & refining
area
water
head box

paper
sheet formation machine

THE
PAPERMAKING drying
PROCESS

surface treatments

= optional process

winding, sheeting

testing &
verification coating, finishing,
of final calendering, cutting
product

labelling, storage, finishing, despatch

despatch & transport and storage area

Figure 2

122
4. Glossary of terms

Additive Substance added to the paper-making process to provide specific

properties of the final paper and board.
Auxiliary chemical A chemical added to a stage of paper-making aimed at improving
the efficiency of a part of the process.
Bleached pulp Pulp which has been subjected to bleaching.
Bleaching Removal or modification to a greater or lesser extent, of wood
resins and coloured components of pulp to improve purity and
brightness.
Calendering Operation carried out on the partially dried paper or board with the
aim of improving the surface finish and printability.
Chemical pulp Cellulose fibres obtained by dissolving and removing the non
cellulose components in wood.
Cleaning A mechanical or hydrodynamic operation to remove unwanted
material from the pulp. Equipment is typically rotating screens or
centrifugal cyclones.
Coating The process of applying to the surface of a paper or board one or
more layers of a liquid suspension containing pigments and binders
to form a superior printing surface on the finished product. The
materials used may include: pigments (clay, talc, calcium
carbonate, etc.), binders (starch, latex, casein, etc.) and auxiliary
substances (dispersing agents, insolubilizing agents, water
retention agents, etc.). Coating is performed either on the paper
machine or as a separate operation which then involves further
drying.
Cutting Dividing one, or simultaneously more than one, web of paper or
board in the cross direction to produce sheets.
De-inking Any process enabling the removal of inks from the fibres. The two
most common types are screening and flotation.
Disintegration The process of converting dry pulp into stock.
Drying The process of reducing the water content of paper and board after
it has left the press section of the paper machine.
Enzymatic Application of biotechnology to the treatment of recycled pulp
treatment* (improvement of characteristics, de-inking, etc.).
Finishing All the operations performed at the mill after the paper machine to
prepare the product for shipment (e.g. separate coating, cutting,
winding, wrapping, labelling etc.).
Head box A vessel, the full width of the paper machine, which ejects stock
through a thin slit on to the moving wire mesh.
Hot dispersion* Pulp treatment operated under pressure using steam at a
temperature close to or more than 100C in order to remove
contaminants from the fibres. Normally, an intense, mechanical
disintegration stage is used.
Machine clothing A set of plastic wires and textile felts conveying and carrying paper
through the paper machine

123
Mechanical pulp Paper-making fibres separated by mechanical means mainly from
wood.
Oxygen treatment * Treatment of the stock made by gaseous oxygen at high
temperature and under pressure.
Ozone treatment * Treatment of the stock made by ozone or oxygen/ozone mix.
Paper machine The machine that produces paper or board. There are different
types of paper-machine depending on the web forming technology
(e.g. four drinier, cylinder, twin wire, single ply, multi-ply, etc.).
Press Two rolls, pressed tightly together, through which the moving web
passes and which removes water by suction and transfer to a
moving textile blanket.
Pulp Material, generally of natural vegetable origin, made ready for use
in paper-making processes by conversion to a mass of individual
fibres.
Pulping Process to convert wood (and other fibrous raw materials) to paper-
making fibres.
Quality System The organisational structure, the procedures, the processes and
the resources that are needed to handle the Quality Management
System).
Recovered paper Paper collected by paper printing and other converting plants and
from other parts of the waste stream which is returned into the
paper-making process by collection and sorting.
Refiner/refining A machine through which paper-making stock is pumped before
delivery to the head-box. The machine imparts heavy mechanical
action to the fibres which modifies their properties in different ways
according to the final properties required.
Re-pulping A process to disintegrate, in water, dry pulp or paper for further
processing.
Semi-chemical pulp Pulp obtained by partial removal from the raw material of those
non-cellulosic components that can be removed by chemical
treatment, for example cooking
Sheet formation See web formation.
Sheeting See cutting.
Slitting Dividing a web of paper or board in the longitudinal direction into
two or more narrower webs.
Special pulping* Pulping with a chemical product (soda, peroxide, etc.).
Stock An aqueous suspension of paper-making pulp.
Stock preparation Process steps for conversion of pulp to stock. Can consist of
disintegration, adding water, fillers and auxiliary chemicals, diluting,
mixing and mechanically treat the paper-making components.
Storage chest A large vessel for storing stock awaiting processing into paper and
board.
Surface treatment Treatment consisting of the application of an appropriate material or
additive to the surface of a paper or a board to change certain
characteristics e.g. printability, porosity, grease-proofness, etc.

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 Thermo-mechanical Paper-making pulp made by mechanical means in combination with
pulp heating, from various raw materials, but usually wood.
Unbleached pulp Pulp that has not been subjected to bleaching.
Virgin pulp Pulp supplied to a paper mill which contains fibres not used before
in the paper-making process.
Washing* Treatment operated on a pulp which is alternately thickened and
diluted and passed through a series of filters with counter-current
flow; the operation is carried out to clean the pulp.
Web The continuous length of paper or board during manufacture or
conversion.
Web formation In the paper machine, the initial process of forming the web by
physical de-watering of the stock.
Winding Operation of rolling-up a web of paper or board.
Wire A closely woven wire mesh, normally made of synthetic fibre, on to
which the paper stock is directed and which then allows the
passage of water away from the moving paper web.

* denotes a process technology that can be applied during various parts of the pulping and paper-making
process but, in this context, only applies to the treatment of recovered paper and board

125
126
 TECHNICAL DOCUMENT No. 5

PRACTICAL GUIDE FOR USERS OF RESOLUTION RESAP

(2002) 1 ON PAPER AND BOARD MATERIALS INTENDED TO
COME INTO CONTACT WITH FOODSTUFFS
Version 2 - 14.11.2007

127
 Table of contents

Page

1. INTRODUCTION ................................................................................................... 129

2. FIELD OF APPLICATION ...................................................................................... 129

3. VERIFICATION OF COMPLIANCE ....................................................................... 130

4. USE OF RECYCLED FIBRES ............................................................................... 137

5. SPECIAL CASES .................................................................................................. 140

6. FUNCTIONAL BARRIER ....................................................................................... 143

7. GENERAL INFORMATION ON TEST METHODS AND STANDARDS ................. 144

8. ABBREVIATIONS ................................................................................................. 145

9. REFERENCES ...................................................................................................... 146

128
1. INTRODUCTION

The Practical Guide is intended for all bodies and persons concerned with the application of
Resolution ResAP (2002) 1 on paper and board materials and articles intended to come into
contact with foodstuffs and the corresponding technical documents. These bodies and
persons are manufacturers and converters of paper and board, food manufacturers and
distributors, enforcement authorities, surveillance bodies and certification laboratories.

The document has no legally binding value. It is intended to provide:

- guidance for a correct application of Resolution ResAP (2002) 1 and the related
technical documents;
- guidelines for checking the compliance of a material or an article;
- explanations to specifications, and background information.

Materials coming into contact with foodstuffs are regulated in EU by the framework Directive
1935/2004/EC, its Amendments and its approximation of the laws of the member states
relating to materials and articles intended to come into contact with foodstuffs. It stipulates
that all kinds of materials and articles intended to come into contact with foodstuffs must be
manufactured in compliance with good manufacturing practice so that, under their normal or
foreseeable conditions of use, they do not transfer their constituents to foodstuffs in
quantities which could endanger human health, bring about an unacceptable change in the
composition of the foodstuffs or a deterioration in the organoleptic characteristics thereof.

Specifications of Resolution ResAP (2002) 1 and the related technical documents are based
on these principles.

2. FIELD OF APPLICATION

2.1. Materials and articles covered by Resolution ResAP (2002) 1

Resolution ResAP (2002) 1 covers paper, board and articles made from paper and/or board
used for all food contact applications under normal or foreseeable conditions of use including
contact with fatty, aqueous or dry foods and for filtering liquids and for high temperature use.
Exceptions are expressed in Chapter 2.2.

Paper is sometimes and board is usually made of several layers. An example is corrugated
board, where one or several layers of fluting are inserted between layers of linerboard.
Another multi-layer product is folding boxboard, where the top and bottom layers may consist
of bleached virgin fibres, while the body of the board may be made of recycled fibres. Every
paper layer must fulfil the requirements of Resolution ResAP (2002) 1, unless separated
from the food by a functional barrier to migration. Further information on functional barrier is
given in Chapter 6.

Resolution ResAP (2002) 1 applies to materials and articles, although major attention is paid
to materials. Articles intended for food contact are, for example, packages, coffee filters,
adsorbent pads containing a layer of paper or cellulosic fibres, paper labels to be fastened to
fruits that will be peeled, moulded fibre articles such as trays for eggs and fruits, filter papers
having a grammage below 500 g/m and disposable tableware.

The manufacturer of articles should consider all auxiliary materials and additives used in the
production of the article, such as printing inks, lacquers, adhesives etc. It is the responsibility
of the manufacturer or importer of the materials and articles intended for food contact, as well
as the persons marketing these materials and articles, to ensure that all elements are in
compliance with the Directive 1935/2004/EC.

129
Many board grades consist of a fibrous layer covered by a so-called mineral coating (the
terms mineral coating, pigment coatings and aqueous pigment coating are synonymous).
These coatings are within the scope of Resolution AP (2002) 1, although they contain
polymeric substances such as binders. Polymeric materials, commonly referred to as plastic
pigments, are also used in some cases as pigments in coatings for paper and board.
Dispersion coatings, which provide barriers against moisture or fats, are within the scope of
Resolution ResAP (2002) 1.

2.2. Materials and articles not covered by the Resolution ResAP (2002) 1

Non-wovens are not classified as paper. They are distinguished from paper in accordance
with ISO 9092.

Filtering layers (as specified by BfR XXXVI/1 of 1999-08-01) with a grammage of at least 500
g/m2 whose main components are synthetic fibres, though they may also contain some
cellulosic fibres.

For the time being there are no regulations dealing with non-wovens or with filtering layers at
European level. However, where these materials are used in contact with food, they should
comply with the Framework Directive.

Kitchen towels and napkins made from paper are not within the scope of Resolution ResAP
(2002) 1. A Technical document on paper kitchen towels and napkins has been elaborated
and is available.

A plastic layer applied to a material or article made of paper is excluded from the scope of the
resolution on paper and board. It should be assessed according to the Directives on plastics
materials and articles.

3. VERIFICATION OF COMPLIANCE

Resolution ResAP (2002) 1 states that papers should be manufactured in accordance with
Technical document No. 4 - CEPI Guide for good manufacturing practice for paper and board for
food contact

Good manufacturing practice (GMP) is the basis of internal surveillance and a fundamental
part of quality control and product safety assurance. A separate document describing GMP
has been elaborated: Technical document No. 4 CEPI Guide for good manufacturing
practice for paper and board for food contact.

Basic elements of GMP include:

Availability of production manuals and instructions

Compliance with specified quality requirements for raw materials
Appropriate storage and handling conditions
The application of processes to avoid or remove contamination
Specification for end-product testing
Information to ensure traceability and to maintain production records

3.1. Multi-layer materials

Typical examples of multi-layer materials are corrugated board and laminates of papers with
other materials such as plastic and/or metal foils.

130
Unless the presence of a functional barrier to the transfer of substances from the paper
layer(s) to foodstuffs can be demonstrated, each paper layer should comply with the
specifications of Resolution ResAP (2002) 1 and related technical documents but tests need
not be carried out for each layer separately. The material is tested as a whole. An example
for assessing compliance is as follows:

For a corrugated board consisting of two layers of board and one of fluting, all layers
containing recycled fibres:

- Each layer should comply with the specifications of Resolution ResAP (2002) 1 and Technical
document No. 3 - Guidelines on paper and board materials and articles, made from recycled
fibres, intended to come into contact with foodstuffs, terms of raw materials, manufacture, use
of substances of Technical document No. 1 List of substances to be used in the manufacture
of paper and board materials and articles intended to come into contact with foodstuffs and the
type of foodstuff with which the material will come into contact.

- Where there is a restriction expressed as QM (QMA) or SML, this restriction refers to the
whole material and must be assessed in terms of the whole material, not for each individual
layer independently.

- Tests for anti-microbial effect and/or sensory tests are done using the whole material.

- Tests to determine compliance with the specific requirements for substances listed in Table
2 of Technical document No. 3 should be carried out on the whole material.

- Adhesives and other possible auxiliary substances should be assessed as well.

Where a layer in a multi-layer material has been shown to act as a functional barrier to
transfer, only the paper layers on the food contact side of the barrier layer need to comply
with the specifications of Resolution ResAP (2002) 1 and related technical documents.
Migration testing can be carried out as described later because the presence of the
functional barrier will prevent transfer from the layers behind the barrier.

3.2. Verification of compliance with specifications of Technical document No. 1 - List of

substances to be used in the manufacture of paper and board materials and articles
intended to come into contact with foodstuffs

3.2.1. Origin of SML and QM (QMA) restrictions

In Technical document No. 1 - List of substances to be used in the manufacture of paper and
board materials and articles intended to come into contact with foodstuffs for some
substances SML restrictions are laid down. The values of SML are identical to those
established for the same substance in EU Directive 90/128/EEC and amendments relating to
plastics materials and articles. These values were based on the restrictions laid down by
SCF/EFSA on the basis of available toxicological documentation. It is recognised that the
toxicological assessments carried out by the SCF/EFSA are based on data supplied for
evaluation of the use of substances in the manufacture of plastics materials and articles and
that they may not be directly applicable for paper and board. However, in the absence of
data more relevant to the use of these substances in paper and board, it would appear
prudent to adopt these restrictions.

The SML restrictions are also expressed on a QM (QMA) basis in the List. The restriction as
QM (QMA) has been derived from the SML restriction by applying the SCF/EFSA convention
of 6 dm2 of material coming into contact with 1 kg of foodstuff and assuming 100% migration.

131
For example, for a substance with an SML restriction of 1 mg/kg food, the restriction
expressed as QMA is 0.17 mg/dm2 paper and board.

For situations where scientific data is established for the SML/QMA ratio which occurs under
normal or foreseeable conditions of use, it is possible to apply the true transfer value which
applies to the case in question to derive the QMA value from the SML restriction for
compliance testing. For example, if the SML/QMA ratio is established as being 0.1, then, for
an SML restriction of 1 mg/kg, the QMA value to be applied is 1.7 mg/dm2, taking into
account the conventional SCF/EFSA contact conditions.

3.2.2. Calculating QMA for contact not corresponding to the SCF conventional ratio

The conventional ratio of 6 dm2 of paper in contact with 1 kg of food adopted for plastics is
not always realistic for many uses of paper. The QM (QMA) restriction to be applied under
normal or foreseeable conditions of use is calculated in accordance with the formula given in
Technical document No. 2 Guidelines on test conditions and methods of analysis for paper
and board materials and articles intended to come into contact with foodstuffs.

3.2.3. Restrictions expressed as QM (QMA)

Testing for compliance of a substance with a restriction expressed as QM (QMA) may be

done either by calculation or by analysing paper and board to determine the total amount of
the substance in the paper.

Determining compliance by calculation

For determination of compliance with the QM (QMA) restriction by calculation it is necessary

to know the mass of the substance used in manufacture and the area of paper manufactured
using this substance. If a worst-case assumption is made that all the substance is
incorporated into the paper, and calculations show that the QM (QMA) is not exceeded, then
the material can be deemed to be in compliance for that substance.

If calculation using this worst-case assumption indicates that the QM (QMA) restriction is
exceeded, but it is known that not all the substance will be incorporated into the paper,
further calculations and/or analysis will need to be carried out. Such calculations shall be
based on scientific evidence and/or experimental studies of the percentage incorporation of
the substance into the finished paper.

Determining compliance by analysis

It is important to note that testing for compliance with a QM (QMA) restriction by analysis
should determine the total concentration of the substance in the paper. The analytical
method used to determine compliance will depend on the substance under consideration.
For some substances, it may be possible to measure the substance in situ, for example by X-
ray fluorescence. Where this is not possible, it will be necessary to separate the substance
from the paper matrix. This may be done by extracting the substance from the paper, or by
degrading the paper matrix, leaving the substance behind, for example by ashing. If
extraction is carried out, extraction conditions must be selected such that as close as
possible to 100% of the substance is extracted. If it is not possible to extract all of the
substance, the percentage extraction should be determined in order that the total
concentration of substance in the paper can be determined. If the paper matrix is degraded,
degradation conditions should be selected such that the substance under examination is not
degraded or volatilised or otherwise lost through the degradation process.

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Expressing values calculated on mass per mass basis as mass per area

Paper manufacturers typically express content of substances in paper in mass per mass
units, for example as milligrams per kilogram of paper (mg/kg). The following formula can be
used to convert a calculated or analytically determined value in mg/kg to a mass per area
basis (milligrams per square decimetre), so that it can be compared with the applicable QMA
restriction (which is expressed as milligrams per square decimetre):

VA (mg/ dm2 ) VM A
100 1000

where:

VA is the calculated or analytically determined value expressed as mass of substance per

unit area of paper (mg/dm2)

VM is the calculated or analytically determined value expressed as mass of substance per

unit mass of paper (mg/kg)

A is the grammage of the paper, expressed as grams per square metre (g/m 2).

Concept of QMA restrictions

The concept of QMA has been adopted for reasons of harmonisation between specifications
laid down in Resolution ResAP (2002) 1 and related technical documents and in EU
Directives.

QMA is a restriction which is expressed in mg (of substance) in the material or article per 6
dm (of surface in contact with food).This restriction is often used in the SCF/EFSA opinion
instead of SML (mg per kg of food)where for the substances under examination a method of
analysis is not available. In this specific case it is assumed that the substance migrates
100% and that 1 kg of food is contact with 6 dm of the material or article.

3.2.4. Restrictions expressed as SML

Testing for compliance with the SML restrictions laid down in Technical document No. 1 - List
of substances to be used in the manufacture of paper and board materials and articles
intended to come into contact with foodstuffs, should be carried out by migration testing,
using the conventional conditions. However, in order to determine compliance with the SML
restrictions laid down in Technical document No. 1 - List of substances to be used in the
manufacture of paper and board materials and articles intended to come into contact with
foodstuffs, extraction tests could be used if, on the basis of scientific evidence, the results
obtained using these tests are at least equal to those obtained by migration testing using the
conventional EU test simulants or foodstuffs.

3.2.5. Verification of compliance with restrictions (QM, QMA, SML)

When testing a material for compliance with restrictions there are two possibilities: testing for
compliance with the QM (QMA) restriction for a substance or testing for compliance with the SML
restriction.

In general, it is envisaged that it is likely to be simpler to test for compliance with the QM (QMA)
restriction for a substance, rather than to test for compliance with the SML restriction for that
substance. It also may be possible to test for compliance with a QM (QMA) restriction by

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calculation. Even if it is not possible to test for compliance by calculation, it is likely to be relatively
simple to carry out an analysis to determine the total amount of substance in the paper (QM).

When the test for compliance with an SML restriction is based on the determination of QM (QMA),
complete transfer of the substance must be assumed (worst case principle). It is not probable that
a substance will transfer completely from a packaging material to a foodstuff in reality, but as the
relation SML/QMA is unknown, complete transfer must be assumed.

There will also be materials for which testing for compliance with the QM (QMA) restriction by
calculation or by analysis indicates that the QM (QMA) restriction will be exceeded. In such a
situation, testing for compliance with the SML restriction should be carried out, if such a restriction
exists.

There are two possibilities for testing for compliance with a restriction expressed as SML: migration
testing or extraction testing.

Migration tests should be designed such that they mimic the contact conditions, which will occur
under normal or foreseeable conditions of use as closely as possible. Tests can either be carried
out using foodstuffs or using so-called simulants, which are intended to mimic foodstuffs.

It should be borne in mind that migration testing for paper and board using a liquid simulant often is
difficult or impossible due to the penetration of the simulant. In this case a more appropriate test,
which might be an extraction test, if adequately designed, could be used.

Extraction tests use solvents in place of foodstuffs. Extraction tests should be designed such that
the results using these tests are equal or higher than those obtained by migration testing.

If for testing compliance using a simulant indicates that the SML restriction is exceeded, testing
can be carried out with foodstuffs of the type which will used in contact with the material in actual
or foreseeable use.

It should be borne in mind that there are no limits set for overall migration for paper, and there is,
therefore, no requirement that such a test be carried out.

The reader should observe that QM (QMA) is expressed as milligrams per square decimetre or
kilogram of paper, whereas SML is expressed as milligrams per kilogram of food or food simulant.

3.2.5.1. Migration testing

Migration tests should be designed such that they mimic the contact conditions which will
occur under normal or foreseeable conditions of use as closely as possible. Tests can either
be carried out using foodstuffs or using so-called 'simulants' which are intended to mimic
foodstuffs.

Technical document No. 2 - Guidelines on test conditions and methods of analysis for paper
and board materials and articles intended to come into contact with foodstuffs specifies time,
temperature and simulants for testing. Further guidance on simulants, substitute test media
and exposure conditions can be obtained in this Practical Guide.

Food has been divided into the following categories: aqueous, alcoholic, fatty and dry, non-
fatty food (see Technical document No. 2). Wherever possible the tests should be done with
the real foodstuffs, however very often it will be necessary to use simulants. The
recommended procedure depends on the nature of the foodstuff as follows:

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Contact with fats and oil

The recommended test simulant is olive oil (or recognised alternative fatty simulants).
Alternatively, testing can be carried out with the actual foodstuff. If contact in actual use will
only be with one side of the paper, then migration tests should be carried out using the food
contact side.

Contact with solid fatty foods with a low-medium moisture content with fat on the surface

Under EU Directives for plastics, for these types of food with fat on the surface, the
designated test simulant is olive oil (or a recognised alternative fatty food simulant or test
medium).

Testing with olive oil may not be appropriate for testing these materials for technical reasons.
Such reasons could include situations where there is complete penetration of the material
when testing with olive oil but where this penetration does not occur in actual use of the
material. In these circumstances, testing should be carried out using foodstuffs or with a
more appropriate test medium. There is currently no generally recognised alternative
simulant available for testing paper contacting these types of food, although studies are
underway in Europe to develop suitable test protocols. In the absence of alternative
recognised tests, it is suggested that materials are tested using extraction tests.

Contact with dry, non-fatty foods

Under EU Directives for plastics, testing is not required for materials and articles contacting
dry foods. However, there is evidence to indicate that there can be transfer of substances
from paper to foods and hence testing is required for paper contacting dry non-fatty foods.
Testing should be carried out using foods or using modified polyphenylene oxide (MPPO) as
food simulant as stated in Technical document No. 2 - Guidelines on test conditions and
methods of analysis for paper and board materials and articles intended to come into contact
with foodstuffs.

It may be worth stating, that the food types as given in Technical document No. 3 -
Guidelines on paper and board materials and articles, made from recycled fibres, intended to
come into contact with foodstuffs are only used for the description of the processing and
additional requirements but not for the testing of compliance with the end-product
requirements.

3.2.5.2. Testing by extraction

Extraction tests can be used in place of migration testing to determine compliance with SML
restrictions provided it can be shown that the extraction tests used give values equal to or
greater than those obtained by migration testing.

The extraction medium should be selected taking into account the type of foodstuff and the
substance being tested for. See Directive 85/572/EEC.

For paper coming into contact with aqueous foods, a recommended extraction solvent is
water, either cold or hot depending on the contact conditions in use.

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3.3. Verification of compliance with specifications of Resolution ResAP (2002) 1 and
Technical document No. 3 Guidelines on paper and board materials and articles,
made from recycled fibres, intended to come into contact with foodstuffs

3.3.1. Anti-microbial effect

Many paper manufacturers add biocides into the water circulation of the paper mill in order to
avoid formation of microbial slime growth. Biocides are intended to act on microbial growth
during the paper-making process and are not intended to be present in the finished paper.
Substances which have an anti-microbial effect on foodstuffs should not be released.

Raw materials and auxiliaries for the production of paper and board sometimes contain
biocides which can be transferred to the end product. An anti-microbial effect caused by
these biocides also has to be avoided.

A CEN standard has been published for the study of possible release of anti-microbial
substances.

3.3.2. Dioxins

Polychlorinated dibenzo-p-dioxins (PCDDs) and dibenzofurans (PCDFs) are halogenated

aromatic compounds that have been identified as contaminants in almost every component
of the global ecosystem. They are, for example, formed during the bleaching of pulp with
chlorine. Consequently the European pulp manufacturers have discontinued bleaching with
elemental chlorine. This has resulted in very low contents of dioxins in European paper.

Worst-case calculations indicate that even if there were to be 100% migration into food,
dioxin levels contributed by paper intended for food contact would be considerably below the
t-TDI (temporary tolerable daily intake) value for dioxins (1 pg/kg bw) recently proposed by
the SCF/EFSA.

Therefore the Committee of experts decided not to include any specific limit for dioxins in the
resolution. Instead there is a requirement for the manufacturer to choose raw materials and
processes in such a way as to make sure that the content of dioxin is as low as possible.

3.3.3. Cadmium, lead and mercury

The restrictions on cadmium, lead and mercury in Resolution ResAP (2002) 1 have been
derived from guideline levels of Resolution AP (96) 4 on maximum and guideline levels and
source-directed measures aimed at reducing the contamination of food by lead, cadmium
and mercury and are based on toxicological assessment, applying the conventional ratio of 6
dm2 of material coming into contact with 1 kg of food and assuming 100 % migration. For
other ratios of paper area to mass of food (see para 6 in Technical document No. 3
Guidelines on paper and board materials and articles, made from recycled fibres, intended to
come into contact with foodstuffs) to determine the QMA value applicable to the specific case
should be determined. There is no restriction indicated for Cr+6, as this would be reduced
during paper manufacture, and can therefore never be identified in a paper or paper product.

Testing for cadmium, lead and mercury is not required for paper intended for contact with
dry, non-fatty food. For fatty and/or aqueous foods, testing is performed from a water extract,
unless the paper is intended for contact with acidic products, such as fruit juice. In this case
3% acetic acid is used as solvent.

CEN has published standards for hot and cold water extraction and ENs to determine
cadmium, lead and mercury.

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3.3.4. Pentachlorophenol and polychlorinated biphenyls

Pentachlorophenol (PCP) is a widely spread, possibly carcinogenic contaminant. PCP was

used in the past as a timber preservative and traces can sometimes be found in paper. It is
now forbidden in products within the EU, although it may still be present in raw materials
imported from elsewhere.

Results of a survey in the UK showed that PCP in paper does not readily migrate into foods.
The QM restriction of 0.15 mg/kg of paper should, therefore, provide an acceptable purity
requirement. The determination is based on extraction with water in the EN standard.

Polychlorinated biphenyls (PCBs) were used in the past in the manufacture of carbonless
copy paper. PCBs are no longer used for this purpose and, hence, modern day carbonless
copy paper does not contain these substances. There is, however, the possibility that
archived papers may contain copy paper containing PCBs. Hence, large batches of archived
papers - if they contain PCB - should not be used as a source for recycled fibres. An EN for
determining PCB is available.

Because there is evidence to indicate that PCBs in paper are no longer a major problem, no
restriction is specified in the Resolution for these substances.

3.3.5. Sensory (organoleptic) characteristics

The main sensory properties of a foodstuff are odour and taste. It is not usual that a material
in contact with food influences the odour of the foodstuff, though the material itself might
have an odour. An odorous food packaging material has no market. Thus, the market is self-
regulating as regards odour of a material intended for food contact.

The taste of a foodstuff is easily affected by surrounding materials. Unsuitable printing inks or
varnishes on the outer surface of a board may transfer constituents to the content of the
package causing an unpleasant change in the taste of the foodstuff. The storage conditions
of a paper or board can cause transfer of taint. The terms taint and off-flavour are both
used to indicate a deterioration in the taste of a foodstuff.

An EN method for testing sensory characteristics is available.

3.3.6. Microbiological quality

Resolution ResAP (2002) 1 states that materials and articles should be of suitable
microbiological quality, taking into account the intended end-use of the material. The
microbiological properties of the end product, i.e. the paper, are usually good, as sheet
making and drying on the paper machine reduces the level of microbiological contamination
significantly. When assessing the microbiological quality of a paper it is, therefore, important
to consider the nature of the food to be packed, its microbiological load and the potential for
the paper to influence this load.

4. USE OF RECYCLED FIBRES

Basic elements, which are particularly important for the production of paper and board made
from recycled fibres intended to come into contact with foodstuffs, are covered in Chapters 3,
5 and 6 of Technical document No. 3 Guidelines on paper and board materials and articles,
made from recycled fibres, intended to come into contact with foodstuffs.

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Furthermore see also Technical document No. 4 CEPI Guide for good manufacturing
practice for paper and board for food contact.

4.1. General aspects

Recycled fibres are used to a great extent in many paper grades, such as newsprint, tissue
and corrugated board. They are also used in some paper grades intended for food contact,
mostly as inner layers in multi-layer materials intended for packing of dry, non-fatty food. A
major volume of recycled fibres originates from recovered paper that has not been deinked,
and sometimes can be identified by its typical greyish colour. Deinked recycled fibres are,
however, very difficult to distinguish from virgin fibres, if at all.

Tests on end products are necessary where there are actual or potential risks to health.
These risks depend on the nature of the recovered paper, the effectiveness and purpose of
recycling treatments and the nature of the contact with foodstuffs for the end-product. All of
these elements are combined with the requirements in Chapter 6 of Technical document
No. 3 Guidelines on paper and board materials and articles, made from recycled fibres,
intended to come into contact with foodstuffs and tied to each other in a matrix (Table 3 in
Technical document No. 3). Descriptions of process technologies given in Technical
document No. 3 provide flexibility to take account of mill-specific circumstances. They are
given as examples but other processes or combination of processes may be used provided
that the end product fulfils the requirements of Chapter 6 of Technical document No. 3. The
purpose of these processes is to reduce or eliminate the presence of contaminants in the
finished product and to fulfil the requirements set in Chapter 6 of Technical document No. 3.
Manufacturers of paper containing recycled fibres shall be able to produce documentation on
the origin of the recycled fibres (the kind of recovered paper that has been used), the main
features of the cleaning process, and the results of analyses. It is in the responsibility of
industry to demonstrate through Good manufacturing practice (see Technical document
No. 4 CEPI Guide for good manufacturing practice for paper and board for food contact)
that the end product meets the requirements of Art. 2 of Council Directive 1935/2004/EC.
More details are given in Chapter 5 and Appendix 1 of Technical document No. 3.

4.2. Recovered paper collecting system

Details of collecting recovered paper and the main sources of recovered paper in Western
Europe can be found in CEPI annual reports.

Further details on quality control at mill entry are given in Technical document No. 4
CEPI Guide for good manufacturing practice for paper and board for food contact.

4.3. Verification of compliance with end product requirements

Analytical methods to be used for testing for compliance with end product requirements are
set out in Technical document No. 2 Guidelines on test conditions and methods of analysis
for paper and board materials and articles intended to come into contact with foodstuffs.

4.3.1. Contact with food to be washed, shelled or peeled

The tests listed in Chapter 6, Table 2 Specific requirements and set out in Technical
document No. 3 Guidelines on paper and board materials and articles, made from recycled
fibres, intended to come into contact with foodstuffs are not required.

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4.3.2. Contact with dry, non-fatty food

Diisopropylnaphthalenes (DIPNs). The main source is recovered carbonless copy paper,

where DIPNs are used as solvents. Several researchers have shown that many paper
grades based on recycled fibres contained significant amounts of DIPNs, and that DIPNs
migrated readily, even into dry food and through an air space. The toxicology of DIPNs has
not yet been fully evaluated, but the toxicological studies showed no reason to set a limit for
the DIPN content. Technical document No. 3 Guidelines on paper and board materials and
articles, made from recycled fibres, intended to come into contact with foodstuffs) state, by
way of precaution, that levels in paper should be kept as low as reasonably achievable.

Partially hydrogenated terphenyls (HTP) also originate from carbonless copy paper and can
be found in recovered paper. As a matter of prudence, Technical document No. 3
Guidelines on paper and board materials and articles, made from recycled fibres, intended to
come into contact with foodstuffs state that levels in paper should be kept as low as
reasonably achievable.

Phthalates are ubiquitous in the environment due to their widespread use in various products
and their slow degradation. They can enter food packaging as additives in adhesives and in
printing inks and varnish. Although printing inks are not in direct contact with food, it has
been shown that the plasticisers they contain can migrate into food through the packaging
material or during storage of reels and bales (set-off phenomenon). Phthalates classified as
Toxic under the 28th Amendment of Dangerous Substances Directive 67/548/EEC are
excluded from printing inks (CEPE exclusion list, September 2001, Selection Criteria A). The
usage of phthalates has been significantly declining since a number of years.

The SCF has established a TDI for some phthalates and the limits are given in EU Directive
90/128/EEC or Synoptic Document. The indicated TDI-values should be converted to SMLs
using the convention TDI x 60 [kg bodyweight/kg food] = SML (TDI is expressed as mass per
mass of body weight, and SML as mass per mass of food).

Volatile solvents originate from gravure printing. Technical document No. 3 Guidelines on
paper and board materials and articles, made from recycled fibres, intended to come into
contact with foodstuffs recommend that solvents should be reduced to the lowest possible
levels in the finished product.

Polycyclic aromatic hydrocarbons (PAHs). Some PAHs are suspected carcinogens. They
occur sometimes as contaminants in, for example, printing inks oils. Under the selection
criteria of the CEPE exclusion list, since years, printing inks do not contain mineral oils or any
other hydrocarbon substances which are classified as Toxic under the Dangerous
Substances Directive 67/546/EEC.

Benzophenone can be present in paper from the use of UV-cure inks and varnishes, where it
is commonly used as a photo initiator. EU Directives for plastics list an SML of 0.6 mg/kg
food for benzophenone.

4.3.3. Contact with fatty and/or aqueous food

In addition to the above analyses the following are recommended:

Michlers ketone (4,4-bis(dimethylamino)benzophenone). This substance, which is a

suspect carcinogen, has seldom been found in paper. It was used in the past as a photo
initiator in UV-cured inks but its use in printing inks for food contact materials is now
prohibited in Europe. Technical document No. 3 Guidelines on paper and board materials
and articles, made from recycled fibres, intended to come into contact with foodstuffs

139
recommend that the migration of this substance shall not be detectable when measured by a
method with a limit of detection of 0.01 mg/kg of food.

4,4-Bis(diethylamino)benzophenone (DEAB) originates also from UV cured printing inks. For

specifications and analysis, see Michlers ketone.

Primary aromatic amines can originate from printing inks. The limit given in Technical
document No. 3 Guidelines on paper and board materials and articles, made from recycled
fibres, intended to come into contact with foodstuffs refers to the sum of the listed amines. A
list of those aromatic amines that are of toxicological concern is given in the 19th amendment
of EU Directive 76/769/EEC (2202/61/EC). Due to the ban in 2002/61/EC these substances
will disappear.

Fluorescent whitening agents (FWAs) are added to many paper grades in order to improve
the apparent brightness of the paper. In the USA and some European countries only a
restricted number of FWAs are allowed in materials in contact with fatty or aqueous food.
FWAs are listed in Technical document No. 1 - List of substances to be used in the
manufacture of paper and board materials and articles intended to come into contact with
foodstuffs, but migration should be not detectable. As the major part of recovered paper
contains FWAs, it is highly probable that paper made of recycled fibres will contain these
substances.

EN 648 specifies the test method for FWAs. The migration of optical brighteners is estimated
visually and noted on a scale from 1 (strong migration) to 5 (no migration). This easurement
should be regarded as a yes/no test: if the mark is 5, there is no migration and the material
can be used in contact with fatty and/or aqueous food. If a value of 4 or lower is obtained,
there is migration and the material is not in compliance.

Certain azo compounds form carcinogenic aromatic amines by cleavage of the azo group(s).
Azo compounds originate from printing inks. The analytical procedure comprises cleaving of
the azo group(s) and determination of the released amines. If the banned amines (see
2002/61/EC, the 19th amendment of EU Directive 76/769/EEC) are found at a content
exceeding 0.1 mg/kg paper, the limit set for azo compounds is exceeded. The limit in
Technical document No. 3 Guidelines on paper and board materials and articles, made
from recycled fibres, intended to come into contact with foodstuffs refer to the sum of the
listed amines. Due to the ban in 2002/61/EC these substances will disappear.

The analytical procedure is given in BfRs Untersuchung von Bedarfsgegenstnde, which

also contains the list of the banned amines. The method is intended for the analysis of
textiles, but it is also may be applicable to paper. It cannot be used for the estimation of
migration into food.

4.3.4. Toxicological tests

The use of toxicological tests and test conditions will be evaluated and they may be
recommended in the future, based on new developments and results in this field. A project to
develop and to validate toxicological tests for paper and board was being funded under the
Fifth Framework programme of the EU (Biosafepaper).

5. SPECIAL CASES

5.1. General considerations

Testing of materials and articles used in more specialised situations is covered in this
chapter. These specialised uses include paper and board used in microwave and

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conventional ovens; paper used in contact with frozen foods; filter papers; disposable
tableware; adsorbent pads.

In general, diffusion (migration) of a substance increases linearly with the square root of time.
Strictly, this applies only when the content of migrant and the mass of the foodstuff are
infinite, but the rule can be applied in most practical cases when an article is in contact with a
foodstuff. Diffusion also doubles with each 10C increase of temperature. Consequently,
short time tests at high temperatures are more severe than long time tests at low
temperature (2 hours at 70C would be more severe than 24 h at 40C).

For the time being, migration from fibrous materials cannot be estimated by current diffusion
models, though some work is being done in this direction. This is due to the heterogeneous
and very complex structure of paper and board.

Where no specific test conditions are given for a specific situation, refer to Technical
document No. 2 - Guidelines on test conditions and methods of analysis for paper and board
materials and articles intended to come into contact with foodstuffs for selection of simulants
and test conditions.

5.2. Use at high temperature

Ovenable boards are used for purposes such as packing ready-cooked meals that are
heated at home in either microwave or conventional ovens. They are differentiated from
baking papers by their generally lower temperature of use and by the fact that they do not
contact fatty foods directly, although they may be used in the heating of fatty foods when
they are separated from the food by a plastic layer.

Baking paper can be used in contact with fatty foods at high temperatures. Test conditions
for baking papers intended for general household use are given in Technical document No. 2
Guidelines on test conditions and methods of analysis for paper and board materials and
articles intended to come into contact with foodstuffs. EU Directives for plastics should be
consulted for test conditions applicable for more specific uses.

When testing ovenable paper and baking paper, degradation products formed at high
temperatures should be taken into account in testing. For further details see Technical
document No. 2.

If migration testing is carried out for paper intended for contact with hot, aqueous liquids,
such as tea bags, coffee filters and cooking pouches the appropriate conditions (time,
temperature and ratio of paper to liquid) should be chosen taking into account the intended
use of the material.

If extraction testing is carried out to determine compliance, hot water extracts should be
prepared.

5.3. Filters and filtering layers

The procedures to be followed when filters made of paper are examined, are described in
Technical document No. 2 Guidelines on test conditions and methods of analysis for paper
and board materials and articles intended to come into contact with foodstuffs. The
procedure is not based on scientific study but, in the absence of suitable data, is pragmatic
and reflects what happens in real use.

Filtering layers are not within the scope of the resolution. The reader may find it useful to
consult BfR XXXVI/1, where testing instructions can be found.

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5.4. Disposable tableware

Contact with fatty and/or aqueous food is foreseeable, and contact temperatures must be
considered from +4 C up to 80 C.

For paper beakers used for hot beverages, testing should be carried out for 1 h at 70C.
Where paper beakers are used for acidic juices, 3% (w/v) acetic acid should be used as a
test simulant.

In principle, paper plates should be tested by filling with a foodstuff or simulant but, because
of technical difficulties, extraction tests may be more appropriate. Isooctane [and 95% v/v
ethanol] shall be used as extraction solvents for tableware contacting fatty foods; testing for
0,5 h at 60C.

5.5. Contact only with food to be washed, shelled or peeled

For materials intended for contact only with foodstuffs to be washed, shelled or peeled, such
as potatoes and apples, the tests listed in Chapter 6 of Table 2 of Technical document No. 3
Guidelines on paper and board materials and articles, made from recycled fibres, intended
to come into contact with foodstuffs are not required. The general requirements of Resolution
ResAP (2002) 1 and of Technical document No. 1 - List of substances to be used in the
manufacture of paper and board materials and articles intended to come into contact with
foodstuffs are valid. Consequently, tests are to be made for pentachlorophenol, for release of
anti-microbial agents and for substances restricted in Technical document No. 1, if these
have been added during manufacture of the material. The same rules apply to moulded fibre
products intended, for example, for eggs.

Typical foodstuffs which are washed, shelled or peeled before eating are for example citrus
fruits, vegetables and peanuts.

5.6. Packages for frozen food

Frozen food that is fatty and/or aqueous is considered as dry, non-fatty food, provided that
the food is not defrosted in contact with paper or board. Consequently, MPPO is a suitable
food simulant for this application. Some examples of conditions for migration testing are
given below.

If the package will not be heated together with the content, as for example when berries are
frozen, and there is no hot fill, 10 days at 5C are the appropriate conditions for migration
testing.

A package may be filled with warm food at 60C, for example a soup, then rapidly frozen and
stored for a long period, and finally heated for 30 minutes to 70C in the pack. This package
should be tested for 1 hour at 70C, only. Any transfer occurring during filling and frozen
storage should be covered by the test conditions proposed. In this case, fatty food simulants
(or alternative simulants or test media) are appropriate for migration testing.

5.7. Vegetable parchment and greaseproof paper

Vegetable parchment is a paper that has been modified by the action of sulphuric acid. This
treatment gives it a high degree of resistance to penetration by organic liquids generally, and
particularly fats, oils and greases (ISO 4046-4).

Greaseproof paper is a paper that has a high resistance to penetration by grease or fats.

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This resistance is obtained by intensive mechanical treatment during stock preparation.

There are also paper and board grades on the market which have been treated with
fluorinated agents to provide grease and oil resistance. Substances used as grease-proofing
agents are typically perfluoroalkyl phosphate esters or amine salts.

Vegetable parchment and greaseproof are intended for contact with fatty and/or aqueous
food. No specific test conditions are given.

5.8. Absorbent pads

The perforated plastic in contact with the food is not a functional barrier. Consequently, for
adsorbent pads containing cellulosic fibres, the fibrous layer should fulfil the specifications of
Resolution ResAP (2002) 1 and the related technical documents for materials in contact with
fatty and/or aqueous food.

6. FUNCTIONAL BARRIER

The efficiency of a functional barrier is defined by a concentration of no concern (an

accepted value) in a food or a food simulant as an end parameter. For all materials, there will
be a time period where the material acts as a barrier to transfer of substances from other
layers behind the barrier or from the environment. However, for some materials, there will
come a time at which substances pass across the barrier and into the food. The time elapsed
between the substances coming into contact with the barrier material and the time at which
the concentration of no concern is exceeded in the food is the time for which that material
acts as a functional barrier. For most materials, the time at which substances come into
contact with the barrier is at manufacture or during converting processes (e.g. printing,
application of adhesives etc.) Hence the start time for a barrier material can be considered as
manufacture or converting, not just when the food is actually packaged in the material.

The full applicability of the functional barrier concept is limited currently by the lack of
agreement concerning the level for a concentration of no concern and the lack of agreed
methods to test whether or not materials act as functional barriers. To some extent,
development of definitive methods is dependent upon the agreement of a level for a
concentration of no concern.

Thus, for the time being, the usefulness of the functional barrier concept is generally
restricted to substances included in Technical document No. 1 - List of substances to be
used in the manufacture of paper and board materials and articles intended to come into
contact with foodstuffs and to other substances for which information is available concerning
their toxicology. For a substance on the list with an SML restriction, a material acts as a
functional barrier for the time over which the material prevents transfer to food exceeding the
SML restriction for that substance. The concept cannot currently be applied to substances for
which no toxicological information is available.

The following discussions on barrier properties refer specifically to transfer of organic

substances.

The barrier properties are influenced by the following factors:

Factors enhancing barrier properties Factors impairing barrier properties

Contact conditions
Low temperature High temperature
Short time Long time

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Material properties
Thick barrier material Thin barrier material
High resistance to diffusion Low resistance to diffusion
Inertness to food Interaction (penetration) with food
Inertness to external factors Interaction with external factors
Continuous layer Discontinuous layer, (pinholes, cracks)

Restricted substances
Low concentration in layers behind the High concentration in layers behind the
barrier barrier

Low mobility, high molecular weight of High mobility, low molecular weight of
contaminants in layers behind contaminants in layers behind the
the barrier barrier

The best barrier materials will be impermeable so as to prevent diffusion. Metal foils are the
most effective barriers provided they are not damaged or too thin. They should, however, not
be placed in direct contact with acidic foods because of corrosion problems.

Various plastics can act as barriers but they are not totally impermeable. Thus they will
generally not have as long a barrier effect as totally impermeable materials. Metallised
plastics layers can act as barriers but are not as effective as continuous foil layers.

Some plastics, whilst not being totally impermeable, do delay transfer of organic substances
significantly. Examples of such materials are polyvinylidene chloride, polyvinyl chloride,
polyethylene terephthalate and polyethylene napthenate. Polyolefins generally do not delay
transfer of organic substances as significantly.

Paper generally has a high permeability and will not generally form an effective barrier to
migration where substances which can transfer across an air space are present.

An air gap could act as a barrier provided that the layer behind the barrier is low in volatile
substances and contact between the food is minimal and the packaging is not subjected to
high temperature.

The effectiveness of foil and other barrier layers is reduced if the layer is not continuous. A
standard procedure for the detection of pinholes in a plastic layer on a paper material was
developed by CEN.

A recognised procedure to demonstrate that an inner layer is a functional barrier would be

welcome. As regards plastics, work is in progress to develop mathematical means based on
kinetic studies in order to find out whether a functional barrier can be deemed to exist.
Diffusion mechanisms are different in porous materials like paper, and other ways might be
needed to study barrier properties.

7. GENERAL INFORMATION ON TEST METHODS AND STANDARDS

The Council of Europe and the EU Commission do not normally issue resolutions or
directives in the field of methods of analysis. The progress in this area is so rapid that any
method may be considered obsolete after a limited number of years. However, there is a
need to provide guidance to analysts who carry out testing to ensure compliance, e.g.
enforcement authorities, industry, retailers and certification laboratories.

It is recommended that internationally recognised and validated methods of analysis are

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applied. For the purpose of this document this includes methods recognised by the following
bodies:

Council of Europe or European Commission;

CEN;
ISO.

References to the test methods can be found in Technical document No. 2 Guidelines on
test conditions and methods of analysis for paper and board materials and articles intended
to come into contact with foodstuffs.

If such a method does not currently exist, an analytical method with appropriate performance
characteristics (accuracy and precision) at the specified limit may be used.

8. ABBREVIATIONS

BfR Bundesinstitut fr Risikobewertung (Federal institute for risk evaluation)

CEN Comit Europen de Normalisation (European Standardisation

Organisation)

CEPE European Council of Paint, Printing Inks and Artists Colours Industry

CEPI Confederation of European Paper Industries

CoE Council of Europe

DIS Draft International Standard

EC European Commission

EN European Standard

FWA Fluorescent Whitening Agent

GMP Good Manufacturing Practice

HACCP Hazard Analysis of Critical Control Points

ISO International Standardisation Organisation

MAFF Ministry of Agriculture, Fisheries and Food (UK)

MPPO Modified polyphenylene oxide (for example Tenax)

QM Maximum quantity of substance in finished product

QMA Maximum quantity of substance in finished product based on area

SCF/EFSA EU Scientific Committee for Food / European Food Safety Authority

SML Specific Migration Limit

TDI Tolerable Daily Intake

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9. REFERENCES

General
EC: Food Contact Materials. Practical Guide.
http://cpf.jrc.it/webpack/

EC: Food Contact Materials. Notes for Guidance. Commission Explanatory Guidance for
migration testing.
http://cpf.jrc.it/webpack/

Bundesinstitut fr gesundheitlichen Verbraucherschutz und Veterinrmedizin (BGVV).

Empfehlung XXXVI.

Nonwoven
ISO 9092.1988. Textiles Nonwoven - Definition

Filtering layers
Gesundheitliche Beurteilung von Kunststoffen im Rahmen des Lebensmittel- und
Bedarfgegenstndegesetzes. 200. Mitteilung. XXXVI/I. Koch- und Heissfilterpapiere und
Filterschichten. Stand 01.08.1999.

Cadmium, lead and mercury

Knezevic, G.: Migration von Metallspuren aus Papier, Karton und Pappe in Prflebensmittel.
Verpackungs-Rundschau, 39 (1988), 67-68.

Sipilinen-Malm, T. et al.: Purity of fibre-based materials. Food Addit. and Contam. 14:6-7
(1997), 695-703.

Derra,R.: Karton aus recyclierten Fasern fr Lebensmittelverpackungen. Wochenbl.

Papierfabrikation 124:5 (1996), 195-197.

DIPNs
Sturaro, A. et al.: Food contamination by diisopropylnaphtalenes from cardboard packages. Int. J.
Food Sci. and Technol. 29:5 (1994), 593-603.

Boccacci Mariani, M., Chiacchierini, E., Gesumundo,C.: Potential migration of Diisopropyl

naphthalenes from recycled paperboard packaging into dry foods. Food Addit. and Contam. 16:5
(1999), 207-213.

Anon.: Diisopropylnaphtalenes in food packaging made from recycled paper and board. MAFF
Food Surveillance Information Sheet No 169 (1999).
http://archive.food.gov.uk/maff/archive/food/infsheet/index.htm

Eisenbrand: Toxikologische Bewertung von Diisopropylnaphthalin, available at VDP, Bonn. This

evaluation gives 56 references, mainly to toxicological aspects.

HTP
Sturaro, A. et al,: Hydrogenated terphenyl contaminants in recycled paper. Chemospere 30:3
(1995), 687-694.

Phthalates
Nerin, C., Cacho, J., Gancedo, P.: Plasticizers from printing inks in a selection of food packages
and their migration into food. Food Addit. and Contam. 10:4 (1993), 453-460.
Aurela, B., Kulmala, H., Sderhjelm, L.: Phthalates in paper and board packagings
and their migration into Tenax and sugar. Food Addit. and Contam. 16:12 (1999), 571-577.

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Benzophenone
Benzophenone from cartonboard. Food Standards Agency UK, Food Surveillance Informa-
tion Sheet Number 6/00, October 2000.
http://archive.food.gov.uk/maff/archive/food/infsheet/index.htm

Pentachlorophenol
Survey of pentachlorophenol in paper and board packaging used for retail foods. MAFF UK
Joint Food Safety and Standards Group, Food Surveillance Information Sheet Number 139,
December 1997.
http://archive.food.gov.uk/maff/archive/food/infsheet/index.htm

Michler's ketone and DEAB

Castle, L., Damant, A.P., Honeybone, C.A., Johns, S.M., Jickells, S.M., Sharman, M.S. and
Gilbert, J. Migration studies from paper and board food packaging materials. Part 2. Survey
for residues of dialkylaminobenzophenone UV-cure ink photoinitiators. Food Addit. and
Contam. 14:1 (1997), 45-52.

Polychorinated biphenyls
Survey of retail paper and board food packaging materials for polychlorinated bisphenyls
(PCBs). MAFF UK Joint Food Safety and Standards Group, Food Surveillance Information
Sheet Number 174, April 1999.
http://archive.food.gov.uk/maff/archive/food/infsheet/index.htm

Rate of migration
Crank, J.: The Mathematics of Diffusion. Oxford Science Publications. 1998.

Council of Europe Resolutions and European Directives

Resolution AP (96)4. Maximum and guideline levels and source-directed measures aimed at
reducing the contamination of food by lead, cadmium and mercury.

82/711/EEC. Council Directive of 18 October 1982 laying down the basic rules necessary for
testing migration of the constituents of plastics materials and articles intended to come into
contact with foodstuffs. Off. J. Eur. Comm. L297, 24.6.81.

85/572/EEC. Council Directive of 19 December 1985 laying down the list of simulants to be
used for testing migration of constituents of plastics materials and articles intended to come
into contact with foodstuffs. L372, 31.12.85.

89/109/EEC. Council Directive of 21 December 1988 on the approximation of the laws of the
Member States relating to materials and articles intended to come into contact with
foodstuffs. L40, 11.2.89.
3/8/EEC. Commission Directive of 15 March 1993 amending Council Directive 82/711/EEC
laying down the basic rules necessary for testing migration of the constituents of plastics
materials and articles intended to come into contact with foodstuffs. Off. J. Eur. Comm. L90,
14.4.93.

97/48/EC. Commission Directive of 29 July 1997 amending for the second time Council
Directive 82/711/EEC laying down the basic rules necessary for testing migration of the
constituents of plastics materials and articles intended to come into contact with foodstuffs.
Off. J. Eur. Comm. L222/10, 12.8.97

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76/769/EEC. Restrictions on the marketing and use of certain dangerous substances and
preparations (azocolourants) - 19th amendment

90/128/EEC Commission Directive relating to plastics materials and articles intended to

come into contact with foodstuffs as amended by 92/39/EEC, 93/9/EEC, 95/3/EC, 96/11/EC
and 99/91/EC

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