The Netherlands has updated its Commodities Act on food-contact materials, issuing an amendment on 26 November 2025. The changes apply retroactively from 1 July 2025 and introduce new migration limits for metals, revised rules for coatings and an updated reference for recycled plastics. The amendment affects manufacturers, converters and suppliers active in the Dutch market and requires a review of existing compliance documentation.
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Key Changes to Metal Packaging
The amendment introduces several notable reductions in specific migration limits (SMLs) for metals used in food-contact packaging. Among the most significant changes are the sharp lowering of arsenic to 0.002 mg/kg, the reduction of cadmium to 0.005 mg/kg, and stricter limits for cobalt and vanadium, reflecting increased regulatory focus on toxicological risk. A particularly substantial revision concerns total lithium compounds, for which the SML has been reduced from 0.6 mg/kg to 0.048 mg/kg.
In addition, the amendment introduces new SMLs for metals that were previously unregulated at national level, including barium (1.2 mg/kg), beryllium (0.01 mg/kg), mercury (0.003 mg/kg), and thallium (0.0001 mg/kg). Limits have also been set for iron, molybdenum, silver, and tin, further expanding the scope of controlled substances in metal food-contact materials.
These changes require metal packaging and components to undergo updated testing, and companies will need to revise declarations of conformity to reflect the new thresholds. A complete overview of all revised and newly introduced SMLs, including the full list of metals and thresholds, is available in our earlier dedicated article on the amendment to the Dutch food-contact metals regulation.
Revisions to Coatings Used in Packaging
The regulation also introduces changes for coatings that come into contact with food. The updated specification for adipic acid dihydrazide (ADH) (Cas No. 1071-93-8) now states that it must not be used in coatings intended for direct contact with acidic foods.
This restriction means manufacturers will need to review coating formulations, particularly those used for canned foods, beverage linings, or packaging intended for acidic products such as fruit, tomato-based foods and vinegar solutions.
In addition, the specific migration limit for adipic acid dihydrazide in final coated products has been raised to 5 mg/kg, replacing the previous limit of 0.05 mg/kg. Companies working with coated metal packaging should confirm whether their current systems remain compliant and whether testing needs to be repeated under the revised limit.
Updated Rules for Recycled Plastic
The amendment replaces the reference to Regulation (EC) 282/2008 with Regulation (EU) 2022/1616, bringing Dutch law in line with the current EU framework for recycled-plastic food-contact materials. This update means packaging made with recycled plastic must follow the newer rules on authorized recycling technologies, system assessment and quality control, as set out in the 2022 regulation. Businesses using recycled material will need to ensure that suppliers and processes meet these updated EU-level standards.
Impact on Packaging Businesses
For metal, coated and recycled-plastic packaging, the amendment raises the compliance bar across the board. Manufacturers must review raw-material specifications, confirm that existing migration test results still apply and update technical files where needed.
Because the regulation applies retroactively from 1 July 2025, companies should verify that products placed on the Dutch market since that date meet the amended requirements. Early checks will help avoid non-compliance issues, especially for high-volume lines or products relying heavily on metal alloys or specialized coatings.
Conclusion
The Netherlands’ 2025 amendment to its food-contact regulations brings stricter controls on metals, updated limits for coatings and a shift to the EU’s latest rules for recycled plastics. For packaging producers and suppliers, the update requires revisiting formulations, confirming test data and ensuring that all food-contact materials placed on the Dutch market since mid-2025 meet the new standards.
