Here’s why it matters:
-
Compliance with food safety regulations
BfR 36/2 is a recommendation. It aligns with EU Regulation 1935/2004, which governs materials in contact with food, making it a recognized benchmark for compliance in Europe. For brand owners, this compliance is critical to avoid regulatory risks and protect consumer health.
"This recommendation exists to ensure alignment of paper products with the EU Regulation 1935/2004. The regulation is very broad and applies to all food-contact materials. For example, regulation article 3 mentions odor and taste, stating that products must not release any smell or flavor that could transfer to food. If the paper smells, it must not transfer to the food”, says Eija Saski, Product Safety & Sustainability Manager from Metsä Greaseproof Papers.
-
Positive list of authorized substances
The recommendation provides a positive list of substances allowed in manufacturing, ensuring that only safe chemicals are used.
"This is correct, confirms Eija. Approved raw materials have undergone a safety assessment. The manufacturer can apply for listing, and the applicant must provide various reports on toxicity for human health. This confirms the product’s safety for the converter. Declaration of compliance with BfR36/2 confirms that approved substances have been used, and the final products do not contain substances in amounts exceeding the limits set by BfR 36/2."
-
Heat resistance & performance
Baking papers must maintain integrity under high heat without affecting food quality. It ensures that papers intended for baking can safely withstand temperatures up to 220°C without decomposing or releasing harmful substances.
The EU Framework Regulation requires that the paper will not transfer unwanted flavors or odors and BfR 36/2 specifies the contaminants that are not allowed to migrate from paper to food, which is crucial for brand reputation and consumer trust.
"To protect brand reputation and consumer trust, it’s best to choose a product that complies with BfR recommendations. For example ISEGA and Eurofins Institut Dr. Rothe GmbH are independent third parties that perform comprehensive evaluations of compliance, when BfR, German Federal Institute for Risk Assessment, is a risk assessment institute." tells Eija.
-
Market access & brand assurance
Many retailers and food brands require BfR-compliant materials as part of their procurement standards. BfR36/2 is a well-known reference in Northern Europe. Also France has its own recommendation (Fiche MCDA n°4 (V02 – 01/01/2019), which does not include a list of approved substances but relies on final product testing.
For converters, certification under BfR 36/2 opens doors to premium markets and strengthens their position as reliable suppliers. For brand owners, it provides a clear safety message to consumers, supporting brand differentiation.
-
Supports food safety goals
BfR does not address compostability or sustainability – it focuses on safety for human health. Good manufacturing practice means the production process is designed for food safety, and this is crucial. BfR 36 is a health and safety standard. It guarantees that food-contact materials can be safely used in contact with food. If compliance cannot be obtained, we make process changes – because we take food safety seriously.