In a significant move to enhance food safety and sustainability, the European Commission has adopted Regulation (EU) 2025/351, which introduces stricter regulations for plastic materials and articles that come into contact with food. Published on February 21, 2025, the updated regulations impose tighter controls on plastic composition, the use of recycled materials, and adherence to good manufacturing practices (GMP).
Key Amendments to Existing Regulations
The new regulation amends three major regulations governing food-contact plastics:
• Regulation (EU) No 10/2011: This regulation sets compositional requirements and safety standards for plastic materials and articles intended to come into contact with food.
• Regulation (EU) 2022/1616: Governs the use of recycled plastic materials in food-contact applications, ensuring the safety and quality of the recycling process.
• Regulation (EC) No 2023/2006: Establishes GMP for food-contact materials, ensuring stringent quality control and safety during the manufacturing process.
The amendments are focused on improving food safety and sustainability by enhancing purity standards, refining migration testing procedures, and providing clearer guidelines for the use of recycled plastics.
Major Updates in Regulation (EU) 2025/351
1. Stricter Rules for Plastic Food Contact Materials (Regulation (EU) No 10/2011)
• Purity & Composition: The regulation defines plastic layers, substances of unknown or variable composition (UVCBs), and sets new purity standards to ensure safety and compliance.
• Migration Testing & Safety: The regulation strengthens migration testing and requires comprehensive risk assessments for non-intentionally added substances (NIAS), ensuring that chemicals do not migrate from plastics into food.
• Reprocessing & Waste Reduction: New rules are introduced for recycling plastic offcuts and by-products, minimizing waste and ensuring safety during reprocessing.
2. Stronger Regulations for Recycled Plastics (Regulation (EU) 2022/1616)
• Higher Safety Standards: Recycled plastics must now meet the same stringent purity requirements as virgin plastics.
• Testing & Documentation: The regulation requires validation of decontamination processes and enhanced traceability to prevent contamination during recycling.
3. Enhanced Good Manufacturing Practices (Regulation (EC) No 2023/2006)
• Manufacturing Practices: Stricter quality control, record-keeping, and assessment standards will be enforced to ensure food-contact plastics are produced safely.
• Reprocessing Controls: New measures for storage, handling, and batch traceability are introduced for reprocessed plastics, further ensuring safety and quality.
Stricter Composition and Migration Testing
The updated regulation clarifies plastic layer definitions, enforces higher purity standards, and distinguishes between additives and starting substances. Additionally, new migration testing methods are being implemented to monitor and control chemical migration, ensuring the safety of both virgin and recycled plastics.
New Labelling and Compliance Requirements
The regulation introduces new labelling requirements for reusable plastics, strengthens the Declaration of Compliance (DoC), and mandates more detailed documentation for regulatory transparency. These measures aim to ensure greater compliance and provide consumers with clearer information about the materials in contact with food.
Phased Compliance Transition
The updated regulations come into force immediately, with businesses given a transition period until September 16, 2026 to comply with the new rules. However, all new food-contact plastics must meet the updated regulations from the publication date onward.
Impact on Industries
The updated regulations will have far-reaching effects on several industries, including:
• Plastic Manufacturing: Manufacturers will need to reformulate plastics, conduct additional safety tests, and source compliant raw materials to meet the new purity and composition standards.
• Food & Beverage Packaging: Companies must replace non-compliant plastics, update packaging suppliers to align with new regulations, and update their labelling and documentation practices.
• Recycling & Waste Management: Stricter safety standards will require improved decontamination, quality control, and traceability during the recycling process.
• Food Production & Retail: Producers and retailers must ensure that food containers and utensils comply with the new regulations, which may require staff training and the adoption of more sustainable packaging alternatives.
Strategies to Address Challenges
To comply with the new regulation, businesses are advised to:
• Proactive Compliance: Implement changes ahead of the enforcement deadline to avoid disruptions.
• Collaboration: Work closely with suppliers, regulatory bodies, and compliance experts to ensure smooth transitions.
• Investment in Testing: Ensure that all food-contact plastics pass updated migration and purity tests.
• Sustainable Innovation: Consider alternative, food-safe materials that may better align with future regulations.
For more information, please refer to the official text of the regulation: Regulation (EU) 2025/351.
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