SGS French Packaging Material Testing

English Translation

On February 10, 2020, the French government promulgated Decree No. 2020-105 concerning the Anti-waste and Circular Economy (AGEC). Article 112 specifically regulates mineral oils. In May 2022, a new ministerial order (Arrêté du 13 avril 2022) was issued to define control targets and limits for mineral oils, extending the enforcement date from January 1, 2022, to January 1, 2023. The regulations implement a phased tightening of standards, with definitions and requirements as follows:

Effective January 1, 2023:

  • The limit for Mineral Oil Aromatic Hydrocarbons (MOAH) consisting of 1 to 7 aromatic rings is 1%.

Effective January 1, 2025:

  • The limit for MOAH (1 to 7 aromatic rings) remains 0.1% (equivalent to the mass concentration limit).

  • The limit for MOAH (3 to 7 aromatic rings) is restricted to 1 ppm (0.0001%).

  • The limit for Mineral Oil Saturated Hydrocarbons (MOSH) consisting of 16 to 35 carbon atoms is 0.1%.

Definitions & Deadlines:

  • Mineral Oil: Refers to oils produced from raw materials derived from petroleum hydrocarbons used in the manufacture of inks.

  • Grace Period: For printed packaging and paper manufactured or imported before January 1, 2023, a disposal period of no more than 12 months from that date is granted.

■ French Environmental Law: Additional Requirements for Packaging Materials

For packaging materials manufactured after June 30, 2001, the sum of concentration levels of Lead (Pb), Cadmium (Cd), Mercury (Hg), and Hexavalent Chromium (Cr6+) shall not exceed 100 ppm (referencing R543-45).

☆ Fast Facts: Mineral Oil

Mineral oil is a complex mixture of diverse hydrocarbons consisting of thousands of compounds with different structures and sizes. While primarily derived from crude oil, it can also be synthetically produced from coal, natural gas, and biomass. Due to its properties in moisture barrier protection, lubrication, and anti-adhesion, it is a versatile additive or solvent commonly used in inks, preservatives, pesticides, glossing agents, lubricants, anti-static agents, softeners, fungicides, and recycled paper.