Food contact materials: what do the new rules state?

Staff Cart-One 19/06/2026 0

When it comes to food safety, packaging is an aspect that must be carefully considered. Especially in the case of primary packaging, which comes into direct contact with food, it is necessary to keep current regulations and their evolution in mind, in order to provide partners with top-level support.

Food packaging manufacturers must not only comply with national provisions but are also required to know the regulations issued at the European level. Recently, Reg. (EU) 10/2011 underwent changes through the XV amendment.

The evolution of FCM regulations and food packaging

Products intended for food contact often involve combining plastic films and paper. The latter must comply with regulations before being placed on the market.

The regulatory framework dealing with Food Contact Materials (FCM) is quite complex and, following the evolution of the packaging market and the introduction of new packaging solutions, it has expanded over time.

Specifically, we can mention Reg. 178/2002, which introduced the theme of packaging safety from a food safety perspective for the first time.

Another step forward is represented by the Framework Regulation for all FCMs through Reg. 1935/2004. In Article 3 of this document, a very important concept is stated: packaging in contact with food must not pose a risk to the consumer, and the organoleptic characteristics of the product must be preserved.

Reg. 2023/2006 focused on Good Manufacturing Practices (GMP). The regulation aims to govern all actions that safeguard the compliance of FCMs at every stage of their life cycle: from production to final use.

Specific regulations: which materials are subject to ad hoc requirements?

European regulations are enriched by five specific regulations concerning materials such as regenerated cellulose, ceramics, active and intelligent materials, plastic objects, and recycled plastic.

Furthermore, there are regulations dedicated to certain starting substances useful for the production of FCMs.

The only materials not subject to a specific regulation are paper and cardboard. In this case, Member States can refer to national standards.

The new Regulation (EU) 1245/2020 - plastic materials and articles intended to come into contact with food: what does the standard prescribe?

Among the most comprehensive and complex documents is certainly Regulation (EU) 10/2011, which concerns plastic materials and articles intended to come into contact with food. The regulation has been revised and amended several times based on natural changes, as well as a new ecological awareness that favors leaner, more sustainable, and recyclable packaging.

A recent amendment, dating back to September 2, 2020, is represented by the XV amendment of the European Commission. Through this document, the aim was to restrict the use of certain substances; therefore, the amendment presents new authorized substances and establishes new migration limits for other substances.

Furthermore, to make the restrictions on the use of certain materials more effective, the XV amendment adds and modifies some of the procedures and conditions present in Annex V, which focused on migration testing.

In essence, the XV amendment replaces Annex II on restrictions for certain materials and also for plastic articles. In this case, we are talking about metals and primary aromatic amines.

The measure also replaced the Declaration of Compliance (DoC), regulated in point 6 of Annex IV.

Other heavy metals have been added to the currently active list of unsafe materials. Among the latter, we can include arsenic, cadmium, lead, mercury, and antimony.

Restrictions are present for certain types of plastics and lanthanides, such as lanthanum, europium, gadolinium, and terbium for polyolefins.

The changes introduced, however, do not eliminate previously established measures. In fact, the modifications apply to production and not to products already placed on the market or present as stock.

To meet these requirements, the product must have been placed on the market for the first time on March 23, 2021.

How to handle multilayer and multi-material packaging?

Another issue closely affecting the paper production and processing sector is multilayer and multi-material packaging.

In detail, if a multilayer packaging has a plastic part that comes into direct contact with food, it must possess all the characteristics required by the regulation.

If the plastic layer is separated from the food by a functional barrier, then other materials not present in the regulation may also be used, provided they are not carcinogenic, mutagenic, or toxic. In such cases, European regulations defer to national laws.

For years, CART-ONE has held a leading position in the production of corrugated cardboard packaging. Thanks to a know-how oriented towards innovation and the search for specific solutions for each customer, we are the perfect partner to support companies in the Food & Beverage sector that want to focus on cutting-edge and eco-sustainable solutions.

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