Notification obligation for distributors of food contact materials and articles

The latest amendments to the Consumer Goods Ordinance were promulgated on April 9, 2024 and came into force on July 1, 2024. The transitional period provided for in the ordinance ends on 31 October 2024. An important new feature is the introduction of a notification requirement for companies that manufacture, handle or place food contact materials and articles on the market (see Section 2a Notification). This addition is intended to improve monitoring and thus consumer health protection. The current version of the Consumer Goods Ordinance can be found here:
 BedGgstV – nichtamtliches Inhaltsverzeichnis (gesetze-im-internet.de)

Here is the new § 2a in question:

§ 2a obligation for notification

(1) Business operators who manufacture, handle or place on the market food contact materials and articles as finished products shall notify the competent authority responsible for the respective establishment at the latest when commencing their activities in accordance with paragraph 2. Sentence 1 shall not apply to food business operators who manufacture, handle or place food contact materials and articles on the market if the establishment in question has already been notified in accordance with Article 6 (2) of Regulation (EC) No. 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs (OJ L 301, 29.4.2004, p. 1). April 2004 on the hygiene of foodstuffs (OJ L 139, 30.4.2004, p. 1; L 226, 25.6.2004, p. 3; L 46, 21.2.2008, p. 51; L 58, 3.3.2009, p. 3), which was last amended by Regulation (EU) 2021/382, has already been registered by the competent authority. The exemption pursuant to sentence 2 shall apply mutatis mutandis to the producers listed in Article 1(2)(c) of Regulation (EC) No 852/2004.

(2) The notification pursuant to paragraph 1 sentence 1 must include the following information:

  1. the name, address and legal form of the company involved in the manufacture, treatment or placing on the market and of the responsible operator,
  2. the name and address of the respective company,
  3. the type of activity of the notifying company, including activities carried out by means of remote communication, and
  4. the group of materials and articles listed in Annex I to Regulation (EC) No. 1935/2004 of the European Parliament and of the Council of October 27, 2004 on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC (OJ L 301, 30.10.2004, p. 1). L 338, 13.11.2004, p. 4), as last amended by Regulation (EU) 2019/1381 (OJ L 231, 6.9.2019, p. 1), which is the main component of the food contact materials and articles manufactured, treated or placed on the market.

(3) The operator shall notify the competent authority of any changes to the information referred to in paragraph 2 no later than six months after the change has occurred if the change still exists at that time.

Heike Schwertke, Oktober 2024 Innoform Testservice (Translation: deepL)