Food Contact Material Regulations Are Evolving Rapidly Across Europe
The European Union continues to strengthen its regulatory framework for Food Contact Materials (FCMs) to ensure that packaging materials do not release harmful substances into food. With growing concerns over chemical migration, endocrine disruptors, and persistent contaminants such as Bisphenol A (BPA) and Per- and Polyfluoroalkyl Substances (PFAS), manufacturers, converters, importers and food businesses are expected to demonstrate higher levels of compliance than ever before. The regulatory landscape now places greater emphasis on migration testing, risk assessment of Non-Intentionally Added Substances (NIAS), Declaration of Compliance (DoC) and full supply chain traceability.
Major Regulatory Developments Impacting Food Packaging
1. Continued Compliance with EU Regulation (EU) No. 10/2011
Regulation (EU) No. 10/2011 remains the principal legislation governing plastic materials and articles intended to come into contact with food. The regulation establishes:
- Union List of authorized substances
- Overall Migration Limit (OML)
- Specific Migration Limits (SML)
- Migration testing conditions
- Declaration of Compliance (DoC)
- Supporting technical documentation
Manufacturers must demonstrate that packaging materials do not transfer substances to food at levels that could endanger human health or alter food composition, taste, or odor.
2. New Restrictions on Bisphenol A (BPA)
Following EFSA’s updated scientific risk assessment, the European Commission adopted Regulation (EU) 2024/3190, significantly restricting the use of Bisphenol A (BPA) and related bisphenols in food contact materials. The regulation entered into force in January 2025 with phased implementation timelines, requiring manufacturers to transition away from BPA-containing materials used in products such as plastic articles, coatings, adhesives and food-contact components.
For manufacturers, this means increased demand for:
- BPA migration testing
- Alternative material verification
- Regulatory documentation supporting compliance
3. Increasing Regulatory Attention on PFAS
PFAS (“forever chemicals”) continue to receive significant regulatory attention due to their persistence and potential health risks.
The EU Packaging and Packaging Waste Regulation (PPWR) introduces stringent restrictions on PFAS in food-contact packaging and begins applying from 12 August 2026. Packaging manufacturers supplying the European market are expected to demonstrate compliance through appropriate analytical testing and supporting documentation.
As a result, PFAS screening has become an important component of packaging safety evaluations.
4. Greater Focus on Declaration of Compliance (DoC) and Traceability
European regulators are increasingly emphasizing:
- Complete Declaration of Compliance (DoC)
- Supporting analytical evidence
- Manufacturing traceability
- Supplier documentation
- Good Manufacturing Practice (GMP)
Testing laboratories now play a critical role in generating the analytical data required to support regulatory documentation and market access.
Why Migration Testing Is More Important Than Ever
Migration occurs when chemical substances transfer from packaging into food during storage or use. The extent of migration depends on factors such as:
- Packaging composition
- Food type
- Contact time
- Temperature
- Surface area
- Intended use conditions
Regulatory authorities require migration studies to ensure packaging remains safe throughout its intended lifecycle.
How Eureka Analytical Services Supports the Tea Industry
Eureka Analytical Services provides comprehensive laboratory solutions to help tea manufacturers, importers, exporters, traders, and brand owners meet evolving regulatory and customer expectations.
Our capabilities include:
- Multi-residue pesticide analysis using LC-MS/MS & GC-MS/MS
- Heavy metal testing using ICP-MS
- Physico-chemical quality analysis
- Microbiological testing
- Export compliance testing for international markets
- Laboratory reports generated under internationally recognized quality systems
- Technical guidance for regulatory compliance and market access
By combining advanced analytical technologies with experienced scientific professionals, Eureka helps businesses demonstrate product safety, maintain compliance, and strengthen customer confidence.
High-Demand Food Contact Material Testing
To support compliance with EU regulations and global customer specifications, manufacturers increasingly require the following analyses:
- Overall Migration Limit (OML)
Determines the total quantity of non-volatile substances migrating from packaging into food simulants under specified conditions.
- Specific Migration Limit (SML)
Measures migration of individual regulated substances that have established legal limits under EU Regulation 10/2011.
- NIAS Screening
Identification and risk assessment of Non-Intentionally Added Substances (NIAS) generated during manufacturing, degradation, recycling, or processing.
- BPA Analysis
Detection and quantification of Bisphenol A to verify compliance with the latest European restrictions.
- PFAS Screening
Targeted analysis for PFAS compounds to support evolving European regulatory requirements and customer expectations.
- Heavy Metal Analysis
Testing for contaminants including:
- Lead (Pb)
- Cadmium (Cd)
- Mercury (Hg)
- Chromium
- Other regulated elements
- Packaging Safety Assessment
Comprehensive evaluation of food contact materials considering migration behaviour, regulatory conformity, intended use and supporting documentation.
How Eureka Supports Food Packaging Compliance
As regulatory requirements continue to evolve globally, Eureka provides comprehensive analytical solutions to help packaging manufacturers, food processors, exporters, converters and brand owners demonstrate compliance with international food contact material regulations.
- Overall Migration (OML) Testing
- Specific Migration (SML) Testing
- NIAS Screening and Risk Assessment
- BPA Analysis
- PFAS Screening
- Heavy Metal Analysis
- Packaging Safety Evaluation
- Technical support for Declaration of Compliance (DoC)
- Regulatory compliance testing for export markets
- Advanced analytical testing using internationally accepted methodologies
By delivering reliable, scientifically validated laboratory data, Eureka helps businesses reduce regulatory risk, support product safety and facilitate access to global markets.
Preparing for Future Compliance
With increasing regulatory scrutiny on food packaging, manufacturers should adopt a proactive compliance strategy by:
- Reviewing packaging formulations against the latest EU requirements
- Conducting routine migration and contaminant testing
- Assessing packaging for NIAS and emerging contaminants
- Updating Declaration of Compliance (DoC) documentation
- Working with accredited laboratories to verify regulatory compliance before products reach the market
Early testing and regulatory readiness can help minimize product recalls, customer non-conformities and trade disruptions while strengthening consumer confidence.
Frequently Asked Questions (FAQ)
1. What are Food Contact Materials (FCMs)?
Food Contact Materials are materials and articles intended to come into direct or indirect contact with food, including packaging, containers, utensils, processing equipment and kitchenware.
2. What is migration testing in food packaging?
Migration testing evaluates whether substances from packaging migrate into food or food simulants at levels that comply with applicable regulatory limits.
3. What is the difference between Overall Migration Limit (OML) and Specific Migration Limit (SML)?
OML measures the total amount of substances migrating from packaging, while SML measures the migration of specific regulated substances with established safety limits.
4. Why is NIAS screening becoming increasingly important?
Non-Intentionally Added Substances (NIAS) may form during manufacturing or degradation. Their identification and risk assessment are becoming increasingly important under European regulatory expectations.
5. How can laboratory testing support packaging compliance?
Laboratory testing helps manufacturers verify migration limits, assess packaging safety, generate technical documentation and support Declaration of Compliance (DoC) requirements.
Official References
- Regulation (EC) No. 1935/2004 on Food Contact Materials
- EU Regulation (EU) No. 10/2011 on Plastic Food Contact Materials
- Commission Regulation (EC) No. 2023/2006 on Good Manufacturing Practice (GMP) for Food Contact Materials
- Regulation (EU) 2025/40 – Packaging and Packaging Waste Regulation (PPWR)
- Commission Regulation (EU) 2024/3190 on Bisphenol A (BPA) Restrictions in Food Contact Materials
- European Food Safety Authority (EFSA) – Food Contact Materials Risk Assessment
- European Commission – Food Contact Materials Framework
