Recommendations are criteria and procedures for verifying the suitability of materials for food contact that have been published by control authorities (e.g. DGCCRF), official bodies (e.g. Council of Europe) or professional organizations (e.g. trade associations). They complement the framework regulation (EC) n°1935/2004, which defines the general and legal requirements that apply to materials and articles intended to come into contact with foodstuffs.

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Why recommendations?

Certain categories of materials listed in Annex 1 of the reglement (CE) n°1935/2004 are not currently the subject of specific regulatory measures in the European Union and France.

To help operators verify the suitability for food contact of materials and objects not covered by regulatory requirements, the DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) has published recommendations on its website for several categories of materials, in particular those for which no specific regulatory measures exist (www.economie.gouv.fr/dgccrf/Materiaux-au-contact-des-denrees-alimentaires).

In addition, a specialized group of experts from the Council of Europe has issued recommendations in the form of Resolutions that can also be used as recommendations to demonstrate compliance with Article 3 of Regulation (EC) No. 1935/2004, which describes the principle of inertia applicable to materials and articles intended to come into contact with foodstuffs.

Where there is no specific regulatory measure or recommendation applicable to a category of materials or articles, Article 3 of Regulation (EC) n°1935/2004 still applies. It is the responsibility of each operator in the supply chain who places substances, raw materials and finished products on the market to demonstrate compliance with these regulatory requirements.

It is the responsibility of each operator in the supply chain who places substances, raw materials and finished products on the market to demonstrate compliance with these regulatory requirements.

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As a complement and to guarantee food safety, the Regulation (EC) n°852/2004 of the Hygiene package defines hygiene requirements for foodstuffs, as well as specific provisions applicable to packaging and wrapping. The implementation of hygiene management measures by operators in the agri-food supply chain enables these requirements to be met.

Consult recommendations by material

Recommendations by material

Similar to the regulatory requirements, the recommendations are presented by category of material, a list of which appears in Annex I of Regulation (EC) n°1935/2004.

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The Council of Europe has also published general recommendations on the principles guiding the adoption of food contact suitability criteria for materials and articles: Resolution CM/Res(2020)9 on the safety and quality of materials and articles for food contact

The sole criterion of wood species set out in the decree of November 15, 1945 is not sufficient to determine the suitability of a finished wooden object for contact with foodstuffs. Wood may contain substances with which foodstuffs can interact. In addition, other constituents of finished wooden objects, such as glues, varnishes, lacquers, paints or inks, are likely to migrate into foodstuffs. Finally, certain wood species are traditionally used in France and temperate European countries and are not listed in the decree of November 15, 1945.

According to the recommendations published by the DGCCRF on its website, other types of wood may be allowed to come into contact with foodstuffs. These include fir, spruce, Douglas fir, maritime pine, Scots pine, poplar, beech, plane, aspen, alder, olive and birch. Wood species not listed in the decree of November 15, 1945 or in the recommendations may also be used, provided that proof is supplied of compliance with article 3 of regulation (EC) n°1935/2004 (Absence of natural substances hazardous to human health migrating from wood, absence of alteration of organoleptic characteristics under the conditions of intended contact with foodstuffs). To guarantee the health safety of wooden objects, a list of active substances that can be used as an anti-blue treatment (fruit and vegetable packaging) is appended to the recommendations, along with a list of undesirable substances. Substances in glues, varnishes, lacquers, paints or inks must be assessed and comply with the migration limits of the specific measures applicable to them (Regulations or Recommendations).

Wood is also a material that can be used in a traditional setting to have a desired effect in food industry technologies such as aging spirits in barrels, ripening cheeses in contact with sheaves, etc. In this context, the woods used are not affected by the intentional release of the wood's natural constituents into these specific foodstuffs.

Wickerwork items, cork objects and bamboo objects are not affected by the recommendations published by the DGCCRF.

Wood in contact with foodstuffs - Information Note 2012-93 of August 16, 2012

On December 1, 2004, the Council of Europe published Resolution ResAP(2004)4 on rubber-based products intended to come into contact with foodstuffs. Its scope includes thermoplastic rubbers as well as mixtures of rubbers with plastics and other materials. This resolution does not apply to rubber soothers, as they are not intended to come into contact with foodstuffs.

The resolution is based on two technical documents:

  • Technical Document No. 1 - List of substances to be used for the manufacture of rubber-based products intended to come into contact with foodstuffs;
  • Technical document no. 2 - Practical guide for the application of Resolution ResAP(2004)4 on rubber-based products intended to come into contact with foodstuffs.

Specific migration limits are required in Technical Document No. 1 for certain substances, and compliance with an overall migration limit (10 mg/dm² of material or 60 mg/kg of food) is required for finished rubber products. The conditions for carrying out migration analyses are those laid down in the regulations applicable to plastics in the European Union (simulant, contact conditions). However, as rubbers are rarely used as packaging materials, the ratio of 6 dm² of material / 1 kg of food is not suitable for calculating migration results. In order to estimate more realistically the migration of components of rubber objects, the Council of Europe resolution proposes to use 4 conventional factors which take into account the relative contact surface (R1), the contact temperature (R2), the contact time (R3) and the number of recurrent uses (R4). The total R factor is obtained by multiplying the four factors to define 3 categories according to intended use (Category I) or migration risk (Categories II and III). These factors are not applicable to migration analysis results for carcinogenic or highly toxic substances that should not be detectable in foodstuffs.

The DGCCRF has also published recommendations on its website concerning rubbers intended to come into contact with foodstuffs, which complement the decree of 9/11/1994 and its amendments.

Resolution ResAP(2004)4

Specific DGCCRF sheet "Rubber"

"Traditional" ceramics are obtained by high-temperature solidification of a plastic wet paste. It is a mixture of inorganic materials, usually with a high clay or silicate content, to which small quantities of organic materials may be added. Ceramic objects are first formed, and the resulting shape is permanently fixed by firing. They can be vitrified, glazed and/or decorated.

In France, in addition to compliance with harmonized regulations, the DGCCRF requires that ceramics do not release aluminum, cobalt and arsenic above thresholds calculated on the basis of toxicological reference values for materials and objects intended to come into contact with food.

MCDA data sheet n°2 (V012 - 01/05/2016)

A glue is a product of liquid, gelatinous or pasty consistency used to bind parts together by contact. There are many types of glue adapted to different uses and materials:

  • Glues of plant or animal origin, such as starch- or casein-based water-based glues;
  • Synthetic adhesives based on vinyl, acrylic, aliphatic, cyanoacrylate, polyurethane, vinyl acetate/ethylene, epoxy, urea/formaldehyde, isoprene, chloroprene, hot melt, silicone, latex ...
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For materials intended to come into contact with food, the main types of glue used are starch-based glues (paper/cardboard), polyvinyl glues (paper/cardboard, wood), urea/formaldehyde-based adhesives (Wood), polyurethane adhesives (plastic complex), polyacrylic and polyvinyl acetate/ethylene adhesives (plastics) and hot-melt adhesives (Paper/cardboard, plastics).

In the European Union and France, in the absence of specific regulatory measures applicable to glues and adhesives, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified with the help of recommendations published by FEICA (Fédération Européenne des Industries des Colles et Adhésifs). FEICA has published 4 guides on glues and adhesives for materials and articles intended to come into contact with food. FEICA recommends ensuring that adhesive components have undergone an authorization or risk assessment based on the requirements applicable to plastics (Regulation (EU) n°10/2011), or even other standards such as the American FDA regulations. FEICA proposes the use of specific provisions for analyzing the migration of adhesive components, taking into account the contribution of carriers. It defines guidelines for the implementation of good manufacturing practices for glues and adhesives in compliance with regulation (EC) n°2023/2006.

Tips for a composition declaration of food contact adhesives- FEICA

Migration testing on adhesives for food contact materials- FEICA

FEICA guide to food contact evaluation for adhesives containing mineral oil hydrocarbons

Enamel is a melting material, composed of silica, feldspar, kaolin and metal oxides vitrified at high temperature to obtain a more or less opaque or transparent and tinted and/or decorated material.

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In the absence of specific regulatory measures applicable to enamel, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified using the recommendations published by the DGCCRF on its website. Taking into account different categories of objects, the criteria adopted relate to limits for the release of lead and cadmium into foodstuffs. For decorated objects, a release limit for chromium VI is also applicable.

Fiche MCDA n°2 (V012 - 01/05/2016)

Printing inks are mixtures of substances that include colorants (pigments, dyes), plasticizers, solvents, binders, driers and additives. They may be water-, solvent- or oleoresin-based, or formulated to be cured by UV or electron beam radiation. Inks can be applied to materials such as plastics, paper, cardboard, natural or synthetic textiles, metals and glass. In their finished state, ink layers are thin films produced by various printing technologies such as flexography, rotogravure, offset, letterpress, screen printing, digital printing or roller coating.

In accordance with Article 3 of Regulation (EC) No. 1935/2004, Regulation (EC) No. 2023/2006, which was published at the end of 2006 and came into force on January 18, 2007, has introduced, since August 1, 2008, rules on good manufacturing practice for materials and objects that also apply to printing inks. This regulation highlights the risks of contamination linked to inks, prohibiting direct contact with foodstuffs, and points out the risks of transfer by smearing between the printed layer and the inner layer of materials. This regulation does not, however, give precise criteria such as lists of authorized substances in ink composition or migration limits for ink components.

Like the European Union, France has not introduced any specific regulatory measures applicable to printing inks. However, an opinion issued by the Conseil Supérieur d'Hygiène Publique de France (CSHPF) on 7/11/1995 specifies that printing inks should not come into contact with foodstuffs, and recommends the use of evaluated colorants listed in circular no. 176 of December 2, 1959, and its various supplements included in the draft French decree notified to the European Commission (Notification no. 2004/328/F). It also contains a list of solvents used in printing inks, with specific migration limits for 12 of them. To help operators in the supply chain, the DGCCRF has published recommendations on its website for printing inks used on surfaces that do not come into contact with foodstuffs. These recommendations take into account the CSHPF opinion and circular no. 176, and add the recommendations of the EUPIA (EUropean Print Ink Association) guide and the Council of Europe's ResAP (2005)2 resolution.

In 2007, the Council of Europe published version no. 2 of the ResAP (2005)2 resolution on packaging printing inks, the result of the work of a group of specialized experts. This resolution is based on three technical documents:

  • Technical document no. 1: Specifications for the selection of packaging printing ink components for application on the surfaces of materials and objects that do not come into contact with foodstuffs;
  • Technical Document No. 2 - Part 1: Good manufacturing practices for packaging printing inks formulated for use on surfaces of materials and objects that do not come into contact with foodstuffs;
  • Technical Document No. 2 - Part 2: Code of good practice for flexible and fiber-based packaging for food contact;
  • Technical Document No. 3: Guidelines on test conditions for packaging printing inks applied to the surfaces of materials and articles that do not come into contact with foodstuffs.

In 2011, the work of the ESCO expert group "Non Plastics Food Contact Materials" addressed the case of inks for printed materials, in particular by making an inventory of substances evaluated or authorized in the countries of the EU and the European Economic Area by comparing the criteria applicable in the various countries that have introduced regulations or evaluated substances used in the composition of inks.

DGCCRF recommendations on printing inks and varnishes

Resolution ResAP (2005)2

Circular no. 176 of December 2, 1959

Notification n°2004/328/F

EUPIA guide

ESCO list

Cork is a material found in the bark of a number of trees, most notably the cork oak. This species of tree is characterized by the subtle formation of its bark, which yields cork. In the agri-food sector, cork is mainly used to seal wine bottles. There are three main types of cork stopper:

  • Natural cork stoppers;
  • clogged corks;
  • cork granulate-based corks;

Other raw materials are used to manufacture cork stoppers:

  • glues for sealing or agglomerating cork;
  • surface coatings to render the cork hydrophobic and obtain the desired coefficient of friction (kerosene, silicone elastomers, kerosene or silicone oils);
  • coloring materials to print the caps.

Cork can, in some cases, impart a musty taste to wines. This is the result of alteration of the cork by molds or bacteria generating the formation of 2,4,6-trichloroanisole and chlorophenols.

In the absence of specific regulatory measures applicable to cork, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified using the recommendations published in the Council of Europe's Resolution ResAP (2004)2. This resolution is based on two technical documents:

  • Technical document No. 1 - List of substances to be used in the manufacture of cork stoppers and other cork materials and articles intended to come into contact with foodstuffs
  • Technical Document No. 2 - Test conditions and analysis methods for cork stoppers and other cork materials and articles intended to come into contact with foodstuffs

Silicone-based cork surface treatments are covered by Council of Europe resolution ResAP (2004)5.

Some substances that may be used in the manufacture of plastics or that may be present in finished plastic products are not on the list of authorized substances in Annex I of Regulation (EU) No. 10/2011. Nevertheless, this regulation allows the use of substances by way of derogation and subject to compliance with rules of use or on condition that they are included in the provisional list of substances (see Article 6 of Regulation (EU) n°10/2011). Thus, colorants, solvents and certain polymer production aids are permitted if they have been authorized by national legislation. In addition, unintentionally added substances (NIAS) or polymerization aids may be present in plastic materials or articles. Also, for all substances without derogation and not listed in European regulations or in national legislation, Article 19 of Regulation (EU) n°10/2011 requires a risk assessment carried out according to internationally recognized scientific principles.

To demonstrate compliance with some of these requirements, the Council of Europe has published resolutions that concern two categories of substances:

  • Polymerization aids that introduce and influence polymer formation are covered by Council of Europe resolution AP (92) 2;
  • Dyeing materials are covered by Council of Europe resolution AP (89) 1.

In France, coloring matters have been evaluated and are listed in circular no. 176 of December 2, 1959 and its various modifiers, and in additional AFSSA opinions. In 2004, the DGCCRF consolidated the list of colorants in a draft decree applicable to plastics. This draft regulation was circulated to the European Commission and EU member states for their opinion (Notification n°2004/328/F). In the end, the draft order was not published. This list of colorants does, however, meet the requirement of Article 19 of EU Regulation n°10/2011 by guaranteeing the existence of a risk assessment, which is also required in the recommendations concerning printing inks, published on the DGCCRF website.

Resolution AP (89) 1

Circular n°176 of December 2, 1959

Notification n°2004/328/F

The European Union has not yet published harmonized legislation applicable to metals. Consequently, in accordance with Article 6 of Regulation (EC) No. 1935/2004, EU member states may maintain or adopt national regulations pending harmonization, under cover of compliance with the mutual recognition principle of Regulation (EC) No. 764/2008. In France, stainless steel, aluminum alloys and tin are covered by regulations. On the other hand, there are no specific regulatory measures for other metal categories.

To help operators in the supply chain, the DGCCRF has published recommendations on its website for coated and uncoated metals and alloys not covered by regulatory texts (Fiche MCDA n°1 - V02 du 01/04/2017). These recommendations take into account the outcome of the Council of Europe's work published in resolution CM/Res (2013)9 of 11/06/2013. Specific release limits are proposed for the various metallic elements, and protocols for carrying out tests are described to take into account the conditions of use of finished objects made of coated or uncoated metals and alloys.

The finished products concerned are metal packaging (beverage cans, canned foods, etc.), parts of metal cooking utensils or household appliances, and metal parts of machines and equipment in contact with foodstuffs in the food industry.

MCDA sheet n°1 - V02 of 01/04/2017

Resolution CM/Res (2013)9 of 11/06/2013

In the absence of specific regulatory measures applicable to paper and cardboard in the European Union and in France, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified using the recommendations published by the DGCCRF on its website (Fiche MCDA n°4 (V02 - 01/01/2019). These recommendations cover materials made from plant fibers, such as paper and cardboard from virgin or recycled fibers, mainly used in primary packaging (sales packaging), secondary packaging (grouping packaging) and tertiary packaging (transport packaging). These recommendations also cover paper and cardboard made from multi-layer materials, as well as coated paper and cardboard, unless a functional barrier can be demonstrated. Circular no. 170 of 2/04/1955 clarifies article 7 of the decree of 28/06/1912 regarding the use of greaseproof or coated paper in contact with food.

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The specifications required in the DGCCRF recommendations concern cellulosic raw materials (virgin fibers or recycled fibers) and other constituents (synthetic fibers, optical brighteners, colorants, biocides). Food contact suitability criteria have been defined according to the risk of migration of substances potentially present in finished products (plasticizers, cross-linking agents, ink photoinitiators, bisphenol A, primary aromatic amines, polycyclic aromatic hydrocarbons, mineral oil hydrocarbons, metallic elements, pentachlorophenol, perfluorooctanoic acid, NIAS: impurities/reaction or degradation products). These substances are likely to be present in recycled fibers which, as a result of previous uses, have been contaminated by additives or production aids as well as by components of coatings, printing inks, varnishes or adhesives.

The Council of Europe has published recommendations in Resolution ResAP (2002) 1 of 18/09/2002 revised in 2005 which can also be used to verify compliance with Article 3 of Regulation (EC) n°1935/2004. This resolution is based on 6 technical documents:

  • Technical document n°1: List of substances to be used in the manufacture of paper and board materials and articles intended to come into contact with food;
  • 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 food;
  • Technical Document No. 3: Guidelines on test conditions and methods of analysis for paper and board materials and articles made from recycled fibers and intended to come into contact with food;
  • Technical document no. 5: Practical guide for users of the ResAP (2002) 1 resolution on paper and board materials and articles made from recycled fibers and intended to come into contact with food;
  • Technical Document No. 6: Guidelines on the presentation of application for safety evaluation of substances to be used in the manufacture of paper and board materials and articles intended to come into contact with foodstuffs.

Finally, CEFIC (Chemical Suppliers), CEPI (Paper and Board Manufacturers), CITPA (Paper and Board Converters) and FPE (Multilayer Paper and Board Manufacturers) have published a guide that provides recommendations for verifying the compliance of paper and board materials and articles intended to come into contact with foodstuffs with Article 3 of Regulation (EC) No. 1935/2004 (Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact of March 2010) . These recommendations are based on chemical purity criteria for paper and board (metallic elements, pentachlorophenol, biocides, Michler's ketone, DEAB, azo dyes, colorants, optical brighteners, polycyclic aromatic hydrocarbons, phthalates, benzophenone and derivatives, DIPN, bisphenol A). The guide also explains the good manufacturing practices applicable to paper and cardboard in order to comply with Regulation (EC) No. 2023/2006, and clarifies the provisions to be put in place concerning traceability.

The non-exhaustive list of products concerned by all these recommendations is as follows:

  • Food packaging such as bags (flour, sugar, fruit and vegetables, bread...), folding papers (wrapping bread, meat....), boxes (eggs, breakfast cereals, rusks...), boxes or sheets for bakers, butchers, caterers, restaurateurs (pastry boxes, pizza boxes, etc.), blotting papers (e.g. exudate blotters for meats, cheeses...) ;
  • Household papers such as baking papers (e.g. greaseproof papers), filter papers, coffee or tea filters, household paper towels, napkins (which are reasonably likely to come into contact with foodstuffs as part of their normal use), tableware (plates, cups...), paper placemats and tablecloths, whose contact with foodstuffs is foreseeable.

MDCDA Datasheet #4 (V02 - 01/01/2019

Resolution ResAP (2002) 1 of 12/02/2009

Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact of March 2010

Technical Guide on Paper and Board Materials and Articles for Food Contact

Materials such as granite, cordierite or lava stone are used for cooking certain foods (pizza, meat, fish, etc.). Natural stone is not one of the materials for which Article 5 of Regulation (EC) no. 1935/2004 lays down specific regulatory measures. However, like all materials and articles intended to come into contact with foodstuffs, cooking stones must comply with Article 3 of Regulation (EC) n°1935/2004.

The instruction of 29/08/1991 from the DGCCRF gives criteria to be required for stones used for heating or cooking food. It is recommended to check the mineralogical composition, in particular the presence of certain toxic elements (lead, cadmium, arsenic, ...) and to analyze the migration of lead and cadmium in acid medium.

Instruction du 29/08/1991

Ion exchange resins are made up of organic macromolecular compounds that include ionizable groups with the property of reversibly exchanging some of their ions on contact with other ions from a solution such as a foodstuff.

In the absence of specific regulatory measures applicable to ion exchange resins in the European Union and France, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified using Resolution ResAP (2004) 3 of 01/12/2004 revised on 03/10/2007. This resolution is based on technical document n°1 "List of substances to be used in the manufacture of ion exchange resins used in the treatment of foodstuffs". This resolution also provides for verification of compliance with migration limits for the substances used in their manufacture.

On 01/12/2004, the Council of Europe published Resolution ResAP(2004)5 on silicone-based products intended to come into contact with foodstuffs. Its scope includes:

  • silicone elastomers such as coatings, sealants, etc.;
  • .
  • silicone fluids used as plastic additives, coatings, release agents for plastic articles, textile impregnants;
  • silicone pastes used as lubricants for food industry machinery;
  • silicone resins used as heat-resistant coatings, non-stick coatings in the food industry such as in bakeries.

The resolution is based on technical document no. 1, which includes a list no. 1 of approved substances and a list no. 2 of non-approved substances for use in silicone materials and articles intended to come into contact with foodstuffs. This resolution specifies that the specific migration limits of the substances on list n°1 should be respected, and that migration analyses should be carried out under the conditions required by EU regulations applicable to plastics.

Resolutions ResAP (2004)5

At present, European Union regulations for materials and articles intended to come into contact with foodstuffs only cover epoxy derivatives of BADGE-based varnishes. The other substances contained in epoxy varnishes are not regulated, apart from BFDGE and NOGE, which are prohibited, and there are no harmonized requirements for other types of varnish.

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On 01/12/2004, the Council of Europe published resolution ResAP (2004)1, the scope of which covers metal packaging coatings, flexible packaging coatings and ultra-resistant coatings. The resolution is based on technical document n°1, which includes:

  • the #1 list of monomers evaluated;
  • the temporary list of unevaluated monomers;
  • The #1 list of evaluated additives;
  • the temporary list of non-evaluated additives.

In addition, the resolution recommends checking the overall migration limit for coatings (10 mg/dm² of material or 60 mg/kg of food) as well as the specific migration limits for monomers and additives on lists #1.

The CEPE (European Council of the Paint and Ink Industry), which participated in the work of the Council of Europe, published, on 02/02/2009, a code of practice for coated articles where the layer in contact with foodstuffs is a coating, which takes up and updates the lists of substances drawn up by the Council of Europe for varnishes.

Resolution ResAp (2004)1

CEEP code

Glass is a non-metallic inorganic material with an amorphous structure that is obtained by the complete fusion, at high temperature, of silica sand with potash or soda ash. Crystal is a type of glass containing a minimum of 24% lead oxide (Directive n°69/493/CEE of December 15, 1969).

In the absence of specific regulatory measures applicable to glass and crystal, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified using the recommendations published by the DGCCRF on its website (Fiche MCDA n°2 (V012 - 01/05/2016). Taking into account different categories of objects, the criteria adopted relate to the limits for the release of lead and cadmium into foodstuffs. For decorated objects, a release limit for chromium VI is also applicable.

MDCDA data sheet #2 (V012 - 01/05/2016)

Vitroceramics are ceramics consisting of microcrystals dispersed in a glassy phase.

In the absence of specific regulatory measures applicable to glass-ceramics, compliance with Article 3 of Regulation (EC) n°1935/2004 can be verified using the recommendations published by the DGCCRF on its website (Fiche MCDA n°2 (V012 - 01/05/2016). Taking into account different categories of objects, the criteria adopted relate to the limits for the release of lead and cadmium into foodstuffs. For decorated objects, a release limit for chromium VI is also applicable.

MDCDA data sheet #2 (V012 - 01/05/2016)