On October 8, 2026, the Government of the Grand Duchy of Luxembourg officially promulgated the "Grand-Ducal Regulation on materials and articles made of metal and metal alloys intended to come into contact with foodstuffs" in the Official Gazette (Mémorial A). The regulation clearly stipulates limit values for the migration of various metal elements into food and sets specific requirements for the labeling of aluminum food contact materials. The regulation entered into force on October 12, 2026.
Key Highlights
1. Definitions and Scope
- Covers materials and articles consisting wholly or partly of metals or alloys that are intended, or can reasonably be expected, to come into contact with foodstuffs, regardless of whether they are coated.
- "Release" refers to the unintended migration of metals into food.
2. Compliance Requirements
- Must comply with EU Regulations (EC) No 1935/2004 and (EC) No 2023/2006 on Good Manufacturing Practice (GMP).
- Specific Release Limits (SRLs) are listed in the Annex: e.g., Aluminum 5 mg/kg, Nickel 0.14 mg/kg, Zinc 5 mg/kg, Cadmium 0.005 mg/kg, Lead 0.010 mg/kg, Mercury 0.003 mg/kg.
- Stricter limits apply to Manganese for infant food (0.07 mg/kg); Tin is set at 100 mg/kg (unless otherwise specified by contaminant regulations).
- A general limit of 60 mg/kg applies to substances without specific limits (excluding Magnesium and Titanium).
3. Testing and Labeling
- Verification must follow official control methods as prescribed by EU Regulation 2017/625, tested under worst-case usage conditions; actual food test results take precedence over food simulants.
- Uncoated aluminum articles must bear the label: "Not to be used for storing, handling, or serving acidic, alkaline, or highly salted foods."
4. Declaration of Compliance and Mutual Recognition
- A written Declaration of Compliance (DoC) is required (template provided in Chapter 2 of the Annex), including manufacturer details, material specifications, and usage restrictions. It remains valid for a maximum of 5 years provided there are no substantial changes.
- Goods lawfully marketed in other EU Member States, Turkey, or EEA countries are subject to the principle of mutual recognition under Regulation (EU) 2019/515.
