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1、Ivan C.K. Chan10 August 20042It is governed under French Decret 92-631 It is identical to EU requirement 89/109/EEC 89/109/EEC -Material and Article in contact with food Regulation -It states the general requirement 1) All product shall be manufactured with good manufacturing practice so that under
2、foreseeable conditions of use. They do not transfer their constituents in quantities that endanger human health; cause any unacceptable change in the composition of the foodstuff.Food grade safety compliance in France 389/109/EEC 2) In article 2, it states that any products in compliance with any EU
3、 national requirement (such as French national requirement, German national requirement, Swedish national requirement) is also in compliance with the said Directive.Food grade safety compliance in France 4When placed on the market, marking requirement as follows : -The words “for food use” or “food
4、grade symbol” -Instruction on how to use the products (unless their nature they are clearly shown) -Any special conditions to be observed when they are being use (eg. not for microwave usage; not suitable for fatty foodstuff) -Company information : 1) Name or trade mark and the address of registered
5、 office or registered trade mark.Food grade safety compliance in France 5Food grade Symbol According to EU 80/590/EEC DirectiveAccording to EU 80/590/EEC DirectiveAny product in compliance with food grade Safety Any product in compliance with food grade Safety can display the following symbol on the
6、 packing or can display the following symbol on the packing or surface of the products. It is defined as “product surface of the products. It is defined as “product for food use”.for food use”.6Testing requirement in France -Well established in French DGCCRF 2004-64 published on 2004 May 6 and Frenc
7、h food regulation book no. 1227 -French Arrete -French Decret -French Avis -French BOCCRFFood grade safety compliance in France 7(A) Plastics -Overall migration test according to 2002/72/EC Directive (follow EU requirement) -Specify 4 foodstuff simulant : 1) Distilled water as aqueous foodstuff (pH
8、4.5); eg. Milk, coffee, egg 2) 3 % acetic acid as aqueous and acidic foodstuff (pH 4.5); eg. Milk, coffee, egg b) 3 % acetic acid as aqueous and acidic foodstuff (pH 4.5); eg. Milk, coffee, egg b) 3 % acetic acid as aqueous and acidic foodstuff (pH 4.5); eg. Milk, coffee, eggFood grade safety compli
9、ance in France 38(L) Coffee machine in contact with foodstuff -Special test according to French DGCCRF 2004-64 (French national requirement no such requirement in EU) -Test divided into several parts 1) Whole unit a) Overall migration test b) Distilled water extractive test; Temperature and conditio
10、n : depends on actual usage condition, select condition as guideline described in EN 1186-1 : 2002 c) Maximum permissible limit : 60 milligram per kilogram of foodstuff in contact withFood grade safety compliance in France 39(L) Coffee machine in contact with foodstuff 2) Any external detachable par
11、t made of metal eg. Metal filter, metal dispenser a) Follow test requirement for metal alloy with or without surface coating 3) Any water tubing made of rubber or silicon rubber (both interior or exterior) -Follow test requirement for rubber except the overall migration test -Follow test requirement
12、 for silicon rubber except the overall migration test Food grade safety compliance in France 40(L) Coffee machine in contact with foodstuff 4) Any external detachable part made of ceramics : eg. Ceramic mug for coffee, glass receiver a) Follow test requirement for glass and ceramicsFood grade safety compliance in France 41Conclusion -Simple item : 1 kind of test stated in section A to K -Complicated item : combination of several tests stated in section A to K.Food grade safety compliance in France