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FCM
NIAS and the New EU Food Contact Materials Regulation: Regulatory Updates, Case Studies, and Testing Strategies

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.

EU Food Contact Materials Regulatory Update: BPA, PPWR and the New Plastic Rules

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 New National Standards for Food Contact Coatings & Silicone Rubber Now in Effect — CIRS Testing Is Ready

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.

Regulatory Alert! EU Reports Food-Contact Material Violations — Excessive Heavy-Metal Migration Accounts for Nearly 70%

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.

Safeguarding Food Contact Safety – Control of Volatile Organic Compounds (VOC) under GB 4806.16-2025

GB 4806.16-2025 National Food Safety Standard – Silicone Rubber Materials and Articles for Food Contact was issued in September 2025 and will be enforced mandatorily in September 2026. The standard introduces a mandatory limit for volatile organic compounds (VOC/volatile matter), directly targeting residual solvents, low-molecular-weight siloxanes, off-odors, and safety risks. This marks a critical gateway for compliance and quality upgrading of food-contact silicone materials.

Official Announcement: China Released New National Standards for Food Safety GB 4806.10-2025 Coatings and GB 4806.16-2025 Silicone Rubber

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

30 Chinese Food Safety Standards Open for Public Comments: Major Revision to General Safety Requirements on Food Contact Materials and Articles

On July 29, 2025, the Secretariat of the National Food Safety Standard Review Committee announced the drafting of 30 national food safety standards, including the National Food Safety Standard-Standard for the Use of Nutritional Fortification Substances in Foods, for public consultation. This initiative is conducted in accordance with the Food Safety Law and its implementing regulations.

China National Standard Updated: 13 High-Risk Additives Banned, Tighter Rules for Colorants and Migration Limits

On July 3, 2025, the China National Center for Food Safety Risk Assessment (CFSA) issued a significant announcement, officially soliciting public comments on the draft revision of the National Food Safety Standard - Standard for Uses of Additives in Food Contact Materials and Articles (Industry Draft for Comments). Commissioned by the National Health Commission (NHC), this revision aims to further enhance the safety of food contact materials.