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21 February 2008

Mr. Manfred Betsch
Heidhöhe 4
B- 4700 Eupen

Subject:          Food Contact Status ofEclipse® 7353/V1749 over
Eclipse® 7252/V1564 over Eclipse® 7050/V1563 non-stick coating system.

All food contact coatings by Whitford are produced according to good manufacturing practice based upon thirty-eight years’ experience of the Whitford Worldwide companies.

This letter provides our assurances that the subject coating system is formulated to fully comply with Commission Directive 2004/1935/EC, as amended, on “Materials and articles intended to come into contact with foodstuffs” which infers that it also meets Council Directive 82/711/EEC of 18 October 1982, as amended, “Laying down the basic rules necessary for testing migration of the constituents of plastic materials and articles intended to come into contact with foodstuffs.”  Thus, provided it is processed in accordance with Whitford’s instructions, this coating system is specifically permitted in all EU Member States for use on food contact articles, including, but not limited to articles such as baking trays, frying pans, dishes, cooking utensils and electrical appliances.

For your application, coating the food contact surfaces of domestic cookware operating at <260°C continuously and/or <285°C intermittently, the subject coating system also meets the compositional requirements of Chapter L1 of Germany’s Kunststoffe im Lebensmittelverkehr of the Bundesinstitut für gesundheitlichen Verbraucherschutz und Veterinärmedizin (Kunststoffempfehlungen des BfR Recommendation L1) on Temperature Resistant Polymer Coating Systems for Frying, Cooking and Baking Utensils.

Under Article 28 (formerly Article 30) of the Treaty Establishing the European Community, which permits the free movement of goods among EU Member States, products containing this coating system may be used as intended in all EU Member States provided that they are first lawfully marketed in another European Union (EU) Member State.

For all commercial and non-commercial food contact applications operating at <260°C continuously and/or <285°C intermittently, this letter provides our assurance that the subject coating system is permitted for use in contact with food in compliance with the Federal Food, Drug, and Cosmetic Act (the “Act”) and all applicable regulations, including 21 CFR 175.300 ("Code of Federal Regulations," the “Code”) provided it is processed in accordance with the manufacturer’s instructions and used in compliance with the Act and regulations

Section 175.300 of the Code states that "Resinous and polymeric coatings may be safely used as the food-contact surface of articles intended for use in producing, manufacturing, packing, processing, preparing, treating, packaging, transporting, or holding food, in accordance with the following prescribed conditions:

“The coating is applied as a continuous film or enamel over a metal substrate, or the coating is intended for repeated food-contact use and is applied to any suitable substrate as a continuous film or enamel that serves as a functional barrier between the food and the substrate.”

This letter of assurance is applicable only to the nonstick coating system described herein.  It is not applicable to material(s) from other vendors to which the nonstick coating system is applied, i.e., metal pretreatments, platings, primers, or metal substrata.  Documentation as to the appropriateness and the FDA status of metal pretreatments, plating, primers, or metal substrata for use in food-contact applications must be obtained from the manufacturers or vendors of these materials, or their scientific and / or legal counsel.

We trust this letter provides adequate assurance as to the regulatory status of this coating system under the laws and regulations administered by the United States Food and Drug Administration and local legislation in Europe.  Please contact me directly if I may be of further service.

Yours sincerely
For the Whitford Worldwide Companies,


Manager, Regulatory Affairs
Whitford Plastics, UK