March 12, 2025
On February 21, 2025, the European Commission (EC) released Commission Regulation (EU) 2025/351 to amend several regulations on food contact materials.
The amended regulations are:
- Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food.
- Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with food.
- Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food, as regards to recycled plastic and other matters related to quality control and manufacturing of plastic materials and articles intended to come into contact with food.
The regulation change goes into effect on March 13, 2025.
Amendments to Regulation (EU) 10/2011 are as follows:
- Changes to the scope of the Regulation, which also covers plastic materials in multi-material multilayer materials
- Insertion of the parameter regarding articles with repeated use that the composition of plastic materials and articles shall be such so as to guarantee that no increase in the migration of constituents of the material or article to the food would occur during their life span when subjected to subsequent use cycles
- Inclusion of the obligation to report on the label, for articles for repeated use, information to mitigate deterioration of the article and a description of the visual changes that indicate deterioration and reaching the end of life, as well as any restrictions in the use of the article when a starting substance is used that is limited by law with respect to times, temperatures and food simulants
- Request for information regarding non-intentionally added substances (if present) in an amount that could cause non-compliance of a final material with Article 3 of Regulation (EC) No 1935/2004
- Introduction of the concept of high degree of purity for raw materials
- Introduction of the possibility by the relevant authorities to take samples to verify their degree of purity and their composition, including that of the substances and materials used for their manufacture
- New reference to plastic wastes
- Introduction of new details regarding the use of reprocessing materials
- Amendment of food simulant to be used for evaluation of specific cheese
- Updating regulatory references to requirements applicable to recycled plastic food contact materials according to Regulation (EU) 2022/1616
- Modification of Regulation (EC) No 2023/2006 on good manufacturing practice for food contact materials according to the Annex II of the new Regulation
Regarding the transitional period, the law establishes that plastic materials and articles complying with Regulation (EU) No 10/2011 as applicable before the entry into force of this Regulation, and any other relevant Union legislation, which were first placed on the market before September 16, 2026, may continue to be placed on the market until the exhaustion of stock.
Business operators will have to revise labels that accompany products as well as declarations for products in contact with food intended for repeated use, aligning with the new provisions. Particular attention must be paid to the declarations submitted by raw material suppliers, which must comply with the new provisions.
UL Solutions can support you in assessing the correctness of the labeling affixed to food contact materials, as well as the formal correctness of the declarations received by raw materials suppliers. UL Solutions can also help your business perform analytical tests and check the declaration of compliance for the finished product.
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