Mid-2025 marks a pivotal wave of updates in food contact material (FCM) regulations across three diverse markets: the Netherlands, Indonesia, and Brazil. While the Netherlands and Indonesia focus on tightening chemical thresholds and harmonizing standards, Brazil sets contaminant standards for recycled cellulosic food-contact materials.
TABLE OF CONTENTS
Netherlands Tightens Chemical Thresholds Across FCMs
The Netherlands introduced amendments to its Commodities Act (effective July 1, 2025, tightening Specific Migration Limits (SMLs) for various substances in materials like plastics, rubber, paper/board, and metals. For example:
- DIBP (Diisobutyl phthalate, CAS No. 84-69-5) in plastics: reduced to ≤ 0.6 mg/kg (from 1 mg/kg)
- Bisphenol A (BPA – CAS No. 80-05-7) in paper/board and metals: tightened to ≤ 0.05 mg/kg
- Chromium, Manganese, Vanadium, DEHP (CAS No. 117-81-7): stricter limits
- Primary aromatic amines (PAAs) added as newly regulated substance, complying with the requirements of Annex II to Regulation (EU) No. 10/2011 (≤ 0,01 mg of substance per kg of food or food simulant. The detection limit applies to the sum of primary aromatic amines released.)
The changes align closely with EU Regulation No. 10/2011, reinforcing EU harmonization efforts.
Indonesia Advances Toward Global Alignment and Safety
Indonesia’s Ministry of Industry has issued a new regulation concerning the mandatory implementation of Indonesian National Standards (SNI) for paper and cardboard used as raw materials in primary food packaging. The regulation covers a broad range of materials (glassine paper, oil-resistant and coated papers, duplex cardboard, laminated paper, and base paper for plastic-laminated wrapping) and analyses:
- General provisions
- The scope of mandatory application of SNI
- Conformity assessment procedures
- Transitional provisions
- Closing provisions
This regulation, which replaces the previous Ministry Regulation No. 20 of 2020, took effect on 24 July 2025, with full compliance required for products manufactured or imported before 24 July 2026. Manufacturers and importers of paper and cardboard for food packaging must comply with the updated standards within the specified timelines, aligning industrial practices with national safety requirements and regulatory expectations.
Brazil Sets Contaminant Standard for Recycled Cellulosic FCMs
Brazil’s Health Regulatory Agency (Agência Nacional de Vigilância Sanitária, Anvisa) issued RDC No. 979/2025 on June 6, 2025, amending the prior RDC No. 88/2016 regulation on cellulosic food-contact materials. The key aspect includes the transposition of Mercosur GMC/Res. No. 02/25 into Brazilian law: “The content of diisopropylnaphthalene (DIPN) (CAS No. 38640-62-9) in the finished product produced from recycled fibers must be as low as technically feasible.” The regulation took effect on June 10, 2025, coinciding with its publication in the Official Journal of the Union (Diário Oficial da União).
This update reflects Brazil’s intent to secure safety in recycled fiber packaging, limiting potential contamination from DIPN through a feasibility-based approach.
Another prior notable update, RDC 961/2025 (February 6, 2025), expanded the approved substance list for plastics and coatings, including:
- TMBPF-DGE (Tetramethyl bisphenol F diglycidyl ether – CAS No. 113693-69-9): limited to 2 mg/kg for aqueous polymer coatings in beverage cans.
- PAI-2 (Polyamide-imide 2 – No CAS Number): allowed only as a binder in high-temperature cookware coatings, with a maximum thickness of 60 µm and capped at 230 °C continuous use (250 °C for short bursts).
Conclusion
The regulatory landscape for food contact materials is widening globally, with the Netherlands having lowered migration limits and reinforced EU-aligned chemical safety standards, Indonesia enhancing protection while moving toward international alignment, and Brazil raising safety thresholds in recycled fiber packaging while continuing to modernize rules for other materials. These updates highlight the importance for packaging producers, converters, and supply chain partners to reassess their compliance and update their quality controls.
