Enamelled surfaces & food contact

We received via our network the following press release of TÜV Rheinland LGA Products GmbH

Release from enamelled objects in contact with foodstuffs – Test methods and permitted limits EN ISO 4531 published.

For some years it has been clear that the test conditions (time, temperature) and also the scope of testing of standard EN 1388-2 “Materials and articles in contact with foodstuffs – Silicate surfaces – Part 2: Determination of the release of lead and cadmium from silicate surfaces other than ceramic ware” of 1995, which dates back to a standard of 1985, are no longer up to date.

According to this standard, the release of lead and cadmium is tested at room temperature over 24 hours in 4% acetic acid. This does not correspond by far to the real use conditions, e.g. of enamelled pots.

Also the view only on lead and cadmium is too narrow in view of various other elements which are released by enamel, e.g. nickel, cobalt, lithium.
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In 2013 the Technical Guideline on Metals and Alloys used in food contact materials and articles (EDQM Guideline/ „Council of Europe Resolution CM/Res (2013) 9“) has been published.

Since the applications of metals and enamel in food contact are very similar, e.g. pots, pans, baking tins, a test according to the EDQM Guideline was used as an intermediate solution.

Recently EN ISO 4531 “Vitreous and porcelain enamels – Release from enamelled articles in contact with food – Methods of test and limits” has been published.

This standard is characterized by the following:
– the real application conditions (time, temperature, repeated use) are considered better.
– 3% acetic acid is used as test medium because it was unanimously agreed that citric acid causes unrealistically severe damage to the enamelled surface.
– a surface/volume ratio of or 5 dm²/l was defined, which is typical for enamel applications (e.g. pots).
– the test temperature for cooking applications is 95°C instead of the usual 100°C.
– the limit values defined in the standard correspond mostly to the limit values as set out in the EDQM Guideline.

For elements used in enamel for technological purposes, higher limit values have been set.

In our according to our information, the new standard is accepted by various surveillance authorities and also by the BfR.

It can be assumed that testing according to this standard is suitable to demonstrate that the enamelled products are safe in food contact within the meaning of Art. 3 Regulation (EC) No. 1935/2004:

„Article 3, General requirements
1. Materials and articles, including active and intelligent materials and articles, shall be manufactured in compliance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer their constituents to food in quantities which could:
(a) endanger human health; or
(b) bring about an unacceptable change in the composition of the food; or
(c) bring about a deterioration in the organoleptic characteristics thereof.“

Additional Note
As part of the revision of the Ceramics Directive 84/500/EEC, it cannot be ruled out that enamel will be included in the scope of a new regulation together with ceramics and glass.

However, the end of the legislative process is not foreseeable at present, so that EN ISO 4531 represents a sensible alternative until then.

Recommendation for Action
We recommend testing according to EN ISO 4531 and can offer this at short notice.

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