Latest Regulatory Update 2026: Food Contact Materials (Packaging) – What Manufacturers Need to Know About EU Compliance

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:

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:

Determines the total quantity of non-volatile substances migrating from packaging into food simulants under specified conditions.

Measures migration of individual regulated substances that have established legal limits under EU Regulation 10/2011.

Identification and risk assessment of Non-Intentionally Added Substances (NIAS) generated during manufacturing, degradation, recycling, or processing.

Detection and quantification of Bisphenol A to verify compliance with the latest European restrictions.

Targeted analysis for PFAS compounds to support evolving European regulatory requirements and customer expectations.

Testing for contaminants including:

Lead (Pb)
Cadmium (Cd)
Mercury (Hg)
Chromium
Other regulated elements

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.