The European Union has adopted a new regulatory framework that introduces stricter requirements in the field of packaging and packaging waste management, with the aim of reducing the negative impact on the environment and encouraging the development of a circular economy.
For food and packaging manufacturers, as well as exporters to the European Union market, this means the need for timely compliance with the new rules. The requirements relate to the design of packaging, its recyclability, the use of recycled materials, reduction of the amount and volume of packaging, proper labeling as well as other aspects of packaging management. The most important changes and obligations and deadlines for implementation are as it follows:
Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food
including requirements
Commission Regulation (EU) 2024/3190 of 19 December 2024 on the use of bisphenol A (BPA) and other bisphenols and bisphenol derivatives with harmonized classification for specific hazardous properties in certain materials and articles intended to come into contact with food, amending Regulation (EU) No 10/2011 and repealing Regulation (EU) 2018/213:
As of 20.07.2026 – prohibition of the presence of bisphenols and their derivatives in packaging made of plastic materials for single use in contact with food, as well as in printing inks, coatings and varnishes (with the exceptions specified in Article 11, with a deadline of 20.01.2028); packaging placed on the market that was produced with the use of bisphenol can be used for food packaging and closed for 12 months after the end of the transition period, and packaged food can be placed on the market until stocks are used up.
Limitation of bisphenol content in paper and cardboard, according to BfR XXXVI. Paper and board for food contact (as of 01.10.2025): the introduction of bisphenol A and other bisphenols into food via food contact materials made of recycled paper/cardboard is currently being considered at the EU level as part of the planned monitoring recommendation issued by the European Commission, with a max of 0.01 mg/kg of food. Until the discussion at European level is concluded, the BfR recommends that the migration of bisphenol A from paper and cardboard materials that come into contact with food into food should be as low as reasonably possible. For bisphenol S: max 0.05 mg/kg.
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (PPWR):
As of 12.08.2026:
- limitation of the total content of Pb, Cd, Hg and Cr(VI) in packaging to 100mg/kg
- • prohibition on placing on the market packaging in contact with food if it contains PFAS compounds – if the content of total F > 50mg/kg, if the sum of PFAS compounds (without polymer PFAS) is > 0.250mg/kg, i.e. individual PFAS compounds > 0.025mg/kg.
Testing of all the mentioned parameters is possible in the SP Laboratorija, in the laboratory of J.S. Hamilton and partner laboratories.
We are available for consultation and support in determining the scope and conditions of packaging testing, as well as in the preparation of the Declaration of compliance (DoC).
Contact: svetlana.boskovic@splaboratorija.rs; splaboratorija@splaboratorija.rs
