Commission Regulation (EU) 2025/351 amends several existing EU regulations on food contact materials, including Regulation (EU) No 10/2011 on plastic materials and Regulation (EU) 2022/1616 on recycled plastics. It also modifies Regulation (EC) No 2023/2006 on good manufacturing practices, with a focus on recycled plastics and quality control in production.
Purity Requirements
Substances used in plastic manufacturing are required to meet high purity standards. They must match their identity, contain only minimal non-intentionally added substances (NIAS), and undergo risk assessments. These substances must either comply with specifications or restrictions, pass toxicological assessments, or ensure migration limits are not exceeded. Documentation confirming purity must be available to competent authorities.
Natural substances, such as UVCB materials (substances of unknown or variable composition, complex reaction products or biological materials), may be used in their original form, provided they do not contain substances that alter their identity.
Biocidal Substances
Biocidal substances authorised under Regulation (EU) No 528/2012 for product-type 4 (products for food and feed area) may be used as additives in plastic materials intended for food contact, as a derogation from the Union list of authorised substances.
Recycled Plastics and Repeated Use
Recycled plastics can be used in food contact materials if they meet strict conditions, including proper collection and compliance with migration limits. For materials intended for repeated food contact, their design must prevent increased migration over time.
New Labelling Requirements
The regulation introduces new labelling rules, including instructions to prevent deterioration and misuse for repeated-use articles. Additionally, materials not yet in contact with food must include usage instructions detailing restrictions on food types, contact time, temperature, or heating conditions. National laws may set migration limits for materials not covered by this regulation.
https://ekotox.eu/food-contact-materials/
https://ekotox.eu/biocides/
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0351