The summer of 2026 brings a series of compliance deadlines for food contact materials in quick succession. Following the bisphenol restriction and the PPWR’s Article 5 chemical requirements, which we covered in our article on what changes for BPA and PFAS in July and August 2026, a third significant deadline arrives on 16 September 2026, when an amendment to Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food applies in full. Unlike the bisphenol and PPWR measures, which introduce new prohibitions, the 10/2011 amendment focuses on raising the standard of substance purity, documentation and non-intentionally added substance (NIAS) characterization across the supply chain.
TABLE OF CONTENTS
What Amendment 2025/351 Introduced
Published on February 24th 2025 and in force since March 16th 2025, Commission Regulation (EU) 2025/351 amends Regulation (EU) No 10/2011 alongside the recycled plastics regulation (EU) 2022/1616 and the GMP regulation (EC) No 2023/2006.
Its central requirement is that substances used in the manufacture of plastic food contact materials must be of a high degree of purity, technically suitable for food contact applications and with a fully known composition. This applies to substances used in both virgin and recycled plastics. If a material contains recycled plastic intended for food contact, it must comply with Regulation (EU) 2022/1616 in full. Manufacturers of reusable plastic food contact articles must also provide end users with clear instructions for correct handling and maintenance, a provision aimed at ensuring that repeated use does not compromise food safety through material deterioration.
The NIAS Dimension
A significant part of the Regulation is the sharpened focus on Non-Intentionally Added Substances (NIAS). NIAS are substances present in the material that were not deliberately added, such as reaction by-products, degradation oligomers or raw material and process impurities. Under the updated framework, manufacturers are expected to have full knowledge of all substances in their materials and to include relevant NIAS findings in Declarations of Compliance passed to the next supply chain stage. This requires analytical testing of the intermediate and the final material, a step that many producers have not yet integrated into their compliance workflow.
Transitional Period and What It Means
Plastic food contact materials that complied with Regulation (EU) No 10/2011 before 16 March 2025 and were first placed on the market before 16 September 2026 may continue to be sold until existing stocks are exhausted. However, materials placed on the market after 16 September 2026 must comply with the amended regulation in full, meaning September 2026 is not just a documentation deadline but also a deadline for production.
There is also a specific documentation obligation for products placed on the market between 16 December 2025 and 16 September 2026 that do not yet comply with Amendment 2025/351: the Declaration of Compliance must explicitly state non-compliance with the amendment and must confirm that the material may only be used in the manufacture of articles placed on the market before 16 September 2026.
What Producers and Traders Need to Do
- Collect updated Declarations of Compliance from all raw material suppliers reflecting compliance with Amendment 2025/351. Supplier DoCs issued under the pre-amendment framework are no longer sufficient after September 2026.
- Establish full knowledge of all substances in the material, including potential NIAS, which in practice requires discussion with suppliers and laboratory testing of the final material.
- Include identified NIAS in the DoC issued to the next stage of the supply chain, and update the DoC to reflect compliance with the amendment.
Conclusion
The 16 September 2026 application date completes the group of food contact compliance deadlines arriving over the summer, alongside the bisphenol restriction and the PPWR’s Article 5 requirements. Whereas those measures introduce new prohibitions, the 10/2011 amendment raise the bar on substance purity, NIAS characterization and supply chain documentation.
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