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Yes, the Council of Europe’s guide for metals and alloys used in food contact materials and articles applies to both coated and uncoated materials when either parts or the entire article are made from metal:
- for non-stick coated metal, the guide applies if the organic surface coating cannot be demonstrated to restrict the release of metal as described in Chapter 1, Article 2, clause 2.2.a of the guide;
- for metal coatings applied on metal, the guide applies since the entire article is made of metal.
For enamelled metal, please see ‘Does the Council of Europe’s guidance on metals and alloys used in food contact materials and articles apply to enamelled cookware?’