2026 marks a watershed year for Food Contact Material (FCM) compliance in the European Union. The new plastics regulation is now in force, and the requirements on Non-Intentionally Added Substances (NIAS) and on the purity of starting substances have become legally binding. Since 16 September 2026, plastic articles produced under the old rules can no longer be placed on the EU market for the first time. RASFF data point in the same direction.
Between July and September 2026, new EU regulations significantly reshaped compliance for food contact materials (FCM). Key changes include a full ban on bisphenol A in single-use FCM, PPWR restrictions limiting PFAS in food packaging, updated purity rules for plastic FCM, and formal PET bottle recycled-content calculation guidelines including chemical recycling. Exporters must now back every shipment with updated Declarations of Conformity, mandatory BPA test reports (1 µg/kg detection limit), and documented PFAS screenings. Furthermore, recent RASFF data highlights bisphenol S, mineral oil, formaldehyde, and primary aromatic amine migrations as top compliance risks requiring routine testing.
China’s mandatory national food safety standards GB 4806.10-2025 (coatings and coated layers) and GB 4806.16-2025 (silicone rubber) took effect on September 2, 2026. The new standards introduce strict requirements, including limits on primary aromatic amines and volatile substances, requiring affected companies to immediately ensure full regulatory compliance.
Recently, the EU Rapid Alert System for Food and Feed (RASFF) reported 15 cases of food-contact materials failing sampling inspections. Of these, 9 originated from China, 1 each from Germany, Japan, and the Netherlands, and 3 from unknown sources. The main reasons for non-compliance in this batch of notifications were: excessive migration of heavy metals — 10 cases; excessive migration of aromatic amines — 3 cases; missing compliance documentation — 2 cases; and insufficient product testing — 1 case.
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), will become mandatorily applicable across the entire EU from August 12, 2026, replacing the 94/62/EC Directive that has been in force for nearly 30 years. PPWR is upgraded into a directly applicable regulation and it imposes full-chain requirements on all packaging placed on the EU marke
On 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) will become fully mandatory. This is not a "recommendatory" guidance document. It is a regulation with direct legal force, uniformly applicable to all EU Member States. From that date onwards, packaging that fails to meet requirements – including excessive heavy metals, non-compliant PFAS levels, incomplete EPR registration, or missing mandatory labels – may face product delisting, customs detention, heavy fines, or even exclusion from the EU market.
In May 2026, the EU Rapid Alert System for Food and Feed (RASFF) issued multiple notifications concerning food contact materials (FCMs). The alerts highlight ongoing compliance issues related to heavy metal migration, primary aromatic amine (PAA) release, and incomplete documentation.
Food contact plastics entering the European market are regulated by EU regulation EU 10/2011. EU legislation is based on the "positive list" principle, where substances used to manufacture food contact plastic materials must be selected from the list in Annex I of EU regulation EU 10/2011. Only substances listed can be added as monomers, additives, or production aids in the manufacturing formula. In the actual production process, apart from substances intentionally added during the process, there are also Non-Intentionally Added Substances (NIAS).
On November 18, 2025, the China National Center for Food Safety Risk Assessment (CFSA) announced a public consultation concerning two new varieties of food-related products, including polyvinyl alcohol.
On September 25, 2025, the National Health Commission and the State Administration for Market Regulation jointly issued Announcement No. 6 of 2025, releasing 32 new national food safety standards and 2 amendments. Among these, four standards related to food contact materials include: GB 4806.10-2025 Coatings and Coatings for Use with Food Contact Materials and Articles GB 4806.16-2025 Silicone Rubber Materials and Products for Food Contact GB 31604.21-2025 Determination of Migration of Benzoic Acid, Phthalic Acid, and Terephthalic Acid in Food Contact Materials and Products GB 31604.64-2025 Determination of Migration of Citrate and Sebacate Compounds in Food Contact Materials and Products
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