EU Approves New Regulation to Amend the Regulations of Plastic Materials for Food Contact

Vol. 1467 | 14 Apr 2025

EU Updates Regulations on Plastic Materials for Food Contact

The European Commission has adopted Commission Regulation (EU) 2025/351, amending the following:

• Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food,
• Regulation (EU) No 2022/1616 on recycled plastic materials and articles intended for food contact, and
• Regulation (EC) No 2023/2006 on good manufacturing practices for such materials.

Key Updates to Regulation (EU) No 10/2011 – Plastic Food Contact Materials

Market Placement Requirements

Plastic materials and articles may only be marketed if they comply with both the new rules on recycled plastics (Regulation (EU) 2022/1616) and all applicable legal standards.

Updated General Requirements for Substances

Substances used in the manufacture of plastic food contact materials must:

• Be of high purity and technically suitable for food-related applications.
• Have fully known compositions—manufacturers must be aware of all components involved.

Reprocessed plastics may only be used if they meet specific regulatory conditions.

New Labelling Obligations

For reusable plastic materials and articles, manufacturers must provide:

• Guidance on how to slow down material degradation,
• Information on visible changes of wear or damage, and
• Warnings about improper use that could increase substance migration or render the item unfit for food contact.

Instructions for Consumer Use

Plastic items intended for food contact but not yet used must come with clear consumer guidance outlining:

• Any restrictions on specific food types or groups,
• Maximum permitted contact time and temperature,
• Heating instructions, including oven or microwave suitability.

Other Amendments

The regulation also introduces changes to:

• Annex III (Food Simulants),
• Annex IV (Declaration of Compliance),
• Annex V (Compliance Testing).

It also includes amendments concerning recycled plastics under Regulation (EU) No 2022/1616 and manufacturing practices under Regulation (EC) No 2023/2006.

Effective date

This Regulation came in to effect on 16 March 2025.

Plastic materials and articles that complied with Regulation (EU) No 10/2011 prior to 16 March 2025 and are first placed on the market before 16 September 2026 may continue to be sold until existing stocks are exhausted.

If a product—whether it is an intermediate material, a substance used in the production of plastic food contact materials, or the material/article itself—complies with Regulation (EU) No 10/2011 before 16 March 2025, but is first placed on the market after 16 December 2025 and does not comply with Commission Regulation (EU) 2025/351, then the Declaration of Compliance must clearly state:

• That it does not comply with Commission Regulation (EU) 2025/351, and
• That it may only be used in the manufacture of plastic materials and articles intended to be placed on the market before 16 September 2026.

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