The European Commission's Regulation (EU) 2025/351, introduced on February 21, 2025, represents a pivotal shift in food safety and sustainability policies related to plastic materials used in food packaging. This regulation updates safety requirements, integrates cutting-edge recycling technologies, and aligns with the EU's broader objectives under the Green Deal and circular economy strategy.

Plastic materials used in food packaging have long been a focus of regulatory oversight due to concerns about chemical migration into food, environmental pollution, and the sustainability of raw materials. With growing consumer awareness and scientific research highlighting the risks associated with certain plastic compounds, the European Union has taken a decisive step to ensure that plastic materials in food contact applications meet the highest safety and sustainability standards.

Key Amendments and Their Implications 

Updating the Framework for Plastic Food Contact Materials

Regulation (EU) No 10/2011 has served as the primary legal framework governing the use of plastic materials in contact with food. However, scientific advancements in material safety and the need for stricter migration limits have necessitated its revision. The amendments introduced in Regulation (EU) 2025/351 impose stricter chemical composition requirements, improve compliance testing methods, and strengthen migration limits for specific substances known to pose health risks.

A key change is the introduction of more rigorous toxicological assessments, particularly concerning endocrine-disrupting chemicals (EDCs) and per- and polyfluoroalkyl substances (PFAS). These substances, commonly found in food packaging materials, have been linked to health concerns, including metabolic disorders and carcinogenic effects. By imposing lower migration thresholds, the new regulation aims to minimize consumer exposure to potentially harmful compounds.

Enhancing Safety Standards for Recycled Plastics

Regulation (EU) 2022/1616, which governs the use of recycled plastics in food contact applications, has also been revised to reflect technological advancements in recycling. Traditional mechanical recycling methods have limitations when it comes to ensuring food safety, particularly regarding the removal of contaminants. The amended regulation now explicitly recognizes chemical recycling as a valid method for producing food-grade recycled plastics.

Chemical recycling processes break down plastics into their molecular components, allowing them to be purified and reassembled into high-quality, food-safe materials. By incorporating these technologies, the EU is not only increasing the proportion of recycled plastics in food packaging but also ensuring that these materials meet the same safety standards as virgin plastics.

Furthermore, the revised regulation mandates stricter traceability requirements for recycled materials. Companies must provide detailed documentation on the origin, processing, and safety assessments of recycled plastics used in food packaging. This transparency helps prevent contamination and ensures compliance with EU food safety laws.

Repealing Outdated Legislation for a More Cohesive Regulatory Approach

Regulation (EC) No 282/2008, which previously governed the use of recycled plastics in food contact materials, has been repealed. The provisions of this outdated regulation have now been integrated into the new legal framework, ensuring a more streamlined and comprehensive approach to food packaging safety. This repeal eliminates inconsistencies between old and new laws and provides a clearer regulatory structure for manufacturers and compliance bodies.

Strengthening Good Manufacturing Practices (GMP) for Plastic Food Packaging

The amendments to Regulation (EC) No 2023/2006 introduce new requirements for the production of plastic food contact materials. These updated standards focus on improving quality control measures, reducing variability in recycled plastics, and ensuring that manufacturing processes align with evolving safety standards.

One of the most significant updates is the emphasis on risk management in manufacturing. Companies must now conduct detailed risk assessments of their raw materials, implement more stringent quality control checkpoints, and adopt technologies that reduce the likelihood of contamination. These measures not only protect consumers but also enhance the overall reliability of recycled plastics as a sustainable alternative to virgin materials.

Scientific Insights and Broader Implications 

Health and Safety Considerations

Scientific research has underscored the risks associated with certain chemicals commonly found in plastic food packaging. A report by the European Food Safety Authority (EFSA, 2024) emphasized the dangers of bisphenols, phthalates, and PFAS in food contact materials, citing potential links to hormone disruption, reproductive issues, and carcinogenicity. The revised migration limits in Regulation (EU) 2025/351 directly address these concerns by imposing stricter safety thresholds and requiring extensive safety assessments before new materials can be approved for use.

Furthermore, microplastics and nanoplastics—tiny plastic particles that can migrate into food—have become a growing area of concern. While research is still ongoing, preliminary studies suggest that ingestion of these particles may have negative health implications. The new regulation incorporates emerging research on microplastic contamination and sets guidelines for minimizing their presence in food contact materials.

Advancing the Circular Economy and Sustainability Goals

The European Union's commitment to a circular economy is evident in its efforts to promote recycled materials while maintaining food safety standards. According to the European Commission's Circular Economy Action Plan (2024), increasing the use of recycled plastics can significantly reduce the environmental footprint of food packaging.

By endorsing chemical recycling, Regulation (EU) 2025/351 expands the potential for high-quality recycled plastics, ensuring that more plastic waste is repurposed rather than incinerated or sent to landfills. This shift supports global efforts to reduce plastic pollution, conserve natural resources, and lower greenhouse gas emissions associated with plastic production.

Industry and Consumer Impact

For manufacturers, the regulation introduces higher compliance costs due to the need for improved testing, documentation, and production controls. However, these costs are offset by the benefits of increased consumer trust, regulatory alignment across the EU, and a more predictable framework for investment in sustainable packaging solutions.

For consumers, the regulation ensures greater safety in food packaging and contributes to broader environmental goals. The shift toward safer, high-quality recycled plastics means that consumers can trust that the food they purchase is not exposed to harmful substances.

Conclusion 

Regulation (EU) 2025/351 marks a significant step forward in ensuring food safety and sustainability in plastic packaging. By updating existing regulations, integrating cutting-edge recycling technologies, and imposing stricter safety measures, the EU has set a new benchmark for plastic materials used in food contact applications.

This regulatory framework not only protects public health but also fosters innovation in the recycling industry and supports the transition to a more sustainable, circular economy. As other regions look to strengthen their food safety laws, the EU's approach may serve as a model for balancing health concerns with environmental and economic priorities.