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EU Food Contact Materials (FCM) Annual Report Released: Analysis of Key Risk Points and Compliance Response Strategies

Time：

2025-06-10

The annual report of the European Union Food Contact Materials (FCM) has been released, with a high focus on the migration of harmful substances and material composition.

Recently, the European Commission released the "2024 Annual Warning and Cooperation Network (ACN) Report", analyzing the warning information and cooperation situation of EU member states in the field of food safety. Among them, the compliance of food contact materials (FCM) remains a core focus of regulatory work.

Source: food.ec.europa.eu

1、 Overall situation reported by EU FCM in 2024

According to the report data, FCM related notifications account for 3% of the total annual notifications in the ACN system, totaling 257 cases. It is worth noting that up to 70% of these FCM notifications are related to potential consumer health risks. This data trend reflects the EU's sustained high attention and strict monitoring of the safety of food contact materials.

2、 Main categories of notifications and analysis of core issues

The report shows that the distribution of notified FCM product categories is shown in the table below, with the combined number of notifications for kitchenware and tableware, as well as disposable products, exceeding half of the total.

FCM Product Category	Proportion of notifications (approximate)
Kitchenware and tableware	34%
Disposable products	22%
Packaging	18%
Food processing equipment	15%
Others (such as baking trays, bottles)	11%

The report shows that FCM's reported issues are highly concentrated in the migration of harmful substances and material composition:

A. Migration of harmful substances

The migration of harmful substances, that is, the phenomenon of chemical components in FCM transferring to the food they come into contact with under specific usage conditions, is the core technical indicator for evaluating the safety of FCM. This type of issue accounts for approximately 50% of the 2024 annual report.

Common migration cases include: formaldehyde migration in melamine tableware exceeding the limit; Due to improper selection of raw materials or production process control, metal and ceramic tableware may exceed the migration limit of heavy metals (such as lead, cadmium, nickel, chromium, etc.); In addition, the migration of phthalates plasticizers, primary aromatic amines (PAAs), and volatile organic compounds (VOCs) has become a potential threat to food safety.

B. Material composition issue

Another major issue is the compliance of the material's own composition, including safety risks caused by the use of unauthorized substances or insufficient material purity. If unauthorized plant-based fillers are illegally used in plastic products, or if bisphenol A (BPA), a substance of high concern to the European Union, is detected in polycarbonate (PC) molds and children's tableware.

C. Other noteworthy issues

Defects in material physical properties, such as corrosion, wear, and detachment of coatings (such as non stick pan coatings), may cause material particles to directly enter food.

Irregular documents and labels: including missing Declaration of Conformity (DoC), incomplete or incorrect label information, and misleading promotion of product characteristics. DoC is a key document proving that a product complies with EU law, and its absence or non-compliance will directly affect the product's market access.

3、 Non compliant FCM source analysis

According to the report statistics, about 75% of non compliant FCM reported products originate from countries outside the European Union. Among them, China is the most frequently mentioned country of origin, accounting for approximately 52% of all cases. EU member states such as Germany, Italy, Spain and Türkiye also have a small number of cases involved.

4、 Enterprise response strategy: Proactively building comprehensive compliance management

Given the various prominent issues revealed in the EU FCM notification mentioned above, companies involved in exporting to Europe need to establish and implement systematic compliance management. This requires companies to strictly monitor and evaluate the safety of materials and products in accordance with the latest EU regulations on food contact materials, including restriction requirements and authorized substance lists. From multiple perspectives such as formula design, supply chain compliance review, and product migration testing, companies are required to manage products exported to Europe and issue accurate and complete Declaration of Conformity (DoC) to ensure compliance with EU regulations.

In addition, enterprises should actively combine the specific expected use of products, target consumer groups, and the latest technological developments to make reasonable material selection, continuously optimize production processes, and improve product performance testing systems, so as to achieve better and more reliable product usage effects while ensuring safety and compliance.

The EU's regulation of food contact materials is becoming increasingly strict, and relevant production and operation enterprises must deeply integrate compliance concepts into various aspects of product research and development, raw material procurement, production process control, and supply chain management in order to effectively prevent potential risks and obtain long-term access to the international market.