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EU - Approved Regulations Amending Regulations on Plastic Food Contact Materials and Articles, Recycles Plastic Materials and Regulations on GMP for Food Contact Materials and Articles

The European Commission has approved Commission Regulation (EU) 2025/351 to amend 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 to come into contact with foods and Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food.

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

Plastic materials and articles may only be placed on the market if they comply with the regulations concerning recycled plastic food contact materials (Commission Regulation (EU) 2022/1616) as well as existing legal requirements.

New General Requirements for Substances

Substances used in the production of plastic food contact materials and articles must meet the following criteria:

  • They must have a high level of purity and be of technical quality suitable for food-related use.
  • Manufacturers must be fully aware of the composition of all substances used in production.

Plastic materials and articles may include reprocessed plastic only if they satisfy specific conditions.

New Labelling Requirements

For plastic materials and articles designed for repeated use, manufacturers must provide the following information:

  • Instructions on how to slow down the deterioration of the material.
  • A description of visible changes that may indicate wear or degradation.
  • Warnings about specific damages or foreseeable misuse that could lead to increased migration of substances or make the article unsuitable for food contact.

Additionally, plastic materials and articles intended for food contact but not yet in use must include consumer instructions. These should outline the restrictions related to one or more of the following elements:

  • Specific foods or food groups.
  • Permitted duration and temperature of contact.
  • Heating conditions, including suitability for ovens or microwaves.

Other amendment include:

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

The amendments about recycled plastic to Regulation (EU) No 2022/1616 and Regulation (EC) No 2023/2006 are also included in this Regulation.

Effective date

This Regulation shall be effective on 16 March 2025. 

Plastic materials and articles complying with Regulation (EU) No 10/2011 before 16 March 2025 which were first placed on the market before 16 September 2026 are able to continue to be placed on the market until the exhaustion of stocks.

In case a product from an intermediate stage of the manufacturing of plastic materials and articles or a substance intended for the manufacturing of such a product, material or article, which complies with Regulation (EU) No 10/2011 before 16 March 2025 and which is first placed on the market after 16 December 2025 does not comply with Commission Regulation (EU) 2025/351, the declaration of compliance shall indicate that it does not comply with Commission Regulation (EU) 2025/351 and that it can only be used in the manufacture of plastic materials and articles to be placed on the market before 16 September 2026.

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