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Effective from March 16th, 2025! EU revises regulations on plastic food contact materials

Time：

2025-03-10

The European Commission has updated the latest revised version of the regulation on plastic food contact materials, namely Regulation (EU) No. 2025/351. This mainly updates the purity requirements for raw materials, processing requirements for plastic waste, and restrictions on the reuse of recycled plastics, which will be implemented from March 16, 2025.

Overview of the Revision of Food Contact Materials (EU) No. 2025/351

On February 24, 2025, the European Commission updated the latest revised version of the regulation on plastic food contact materials, namely Regulation (EU) No. 2025/351. This update is the 18th update to the regulation since its release, mainly updating the purity requirements for raw materials, processing requirements for plastic waste, and restrictions on the reuse of recycled plastics. The new revised content will come into effect on March 16, 2025.

Update on purity requirements for raw materials

The most important part of this update and revision is that the European Union has issued new raw material requirements for plastic food contact materials, which clearly limit the impurities in the materials.

01. New clause Article 3a

In the document released by the European Commission, a new Article 3a regulation has been added. The new clause states that the raw materials used to manufacture plastic food contact materials need to ensure their high purity. The raw materials should only contain a very small amount of impurities and should be unintentional additives (NIAS). The specific requirements for impurities should meet one of the following conditions, otherwise they will be considered as additional additives.

1. Impurities comply with the specifications or limitations specified in Table 1 of Annex I of the regulations

2. According to Article 19 of the regulations, impurities have passed the risk assessment and comply with relevant regulations

3. The impurities have been subjected to toxicological evaluation in accordance with the relevant requirements of the European Union and do not contain genetic toxicity. And in subsequent processing, no impurities will appear in the final product of food contact materials and products, or their content will be ≤ 0.05 mg/kg

4. Impurities have not been officially assessed by the European Union, but in subsequent processing, any impurity will not appear in the final product of food contact materials and products, or its content is less than or equal to 0.00015 mg/kg

02. Special exemptions

For recycled plastic materials that comply with Regulation (EU) 2022/1616 and products that have undergone decontamination processes, the raw materials do not need to meet the purity requirements mentioned above.

But if additional substances are added in the regeneration process, intentional additives still need to meet the above purity requirements.

Requirements for processing plastic waste materials

This regulatory revision and update also proposes to add processing requirements for off cuts and scraps of plastic raw materials in the GMP regulation (Regulation (EC) 2023/2006).

Interpretation of the original text of regulations

We can briefly summarize the specific requirements and restrictions for reprocessing plastic waste materials as follows:

Plastic scraps, scraps, and other plastic by-products that need to be reprocessed should be stored separately from waste, and the storage location should be as close as possible to the site where the waste plastic is manufactured/cut;
A dedicated closed pipeline or belt system should be used to collect residual materials for reprocessing, or they should be collected in a dedicated clean container. These containers should be closed immediately after being filled to avoid cross contamination before reprocessing.
The container for storing leftover materials can be transferred separately for reprocessing, or grouped and placed in secondary packaging. The definition of "batch" in Regulation (EU) 2022/161 must be followed.
At all stages of reprocessing, it is important to avoid mixing plastic scraps with materials or waste of different compositions. When transferring plastic waste materials from different batches, corresponding records must be kept to ensure traceability of material sources.

Reuse of recycled plastics

For environmental reasons, the European Union does not advocate the use of disposable plastics. Therefore, in recent years, many products using recycled plastics have appeared in the EU market. The revision of the regulations on food contact materials this time also proposes new regulations for this type of product.

01. Requirements for the product

For reusable recycled plastic products themselves, the EU requires that the migration of related substances should decrease with increasing usage.

This is to ensure that the relevant substances will not accumulate continuously according to the duration of use, thereby ensuring the quality and safety of the products in contact, which is beneficial to human and environmental health.

02. Label requirements

According to EU requirements, manufacturers must provide the following information on product labels for plastic materials and reusable recycled plastics:

Instructions for slowing down material deterioration.
What traces or changes should consumers use to determine the description of product wear or aging.
Warning for actions that may lead to the following situations
Increased amount of material migration
Specific wear and tear changes that render the product unsuitable for food contact
Foreseeable misuse

In addition, for plastic products intended for food contact, manufacturers also need to provide additional instructions to consumers, which should include one or more of the following relevant elements:

Specific foods or food categories.
The time and temperature allowed for plastic packaging to come into contact with food.
Heating conditions, including whether they are suitable for ovens or microwaves.

Effective Date

The revised content will take effect on March 16, 2025, and products that are first launched on the market before September 16, 2026 can continue to be sold until the product inventory is exhausted. Intermediate materials that comply with the old regulations and are first placed on the market after December 16, 2025, but do not comply with the (EU) 2025/351 regulation, must indicate in the accompanying declaration of conformity that they do not comply with the regulation and can only be used to manufacture plastic materials and products placed on the market before September 16, 2026. European Union