EU Food-Contact Plastics: 16 September 2026 Compliance Deadline

For EU buyers, 16 September 2026 was a practical compliance cut-off for plastic food-contact materials under Regulation (EU) 2025/351. Plastic food-contact materials and articles that complied with the previous rules and were first placed on the market before that date may continue to be sold until stocks are exhausted. Products first placed on the market after the cut-off should be assessed against the current requirements. This is a transition rule, not a blanket ban on plastic packaging.

Why the deadline matters to packaging buyers

Airline caterers, foodservice distributors and private-label buyers often source several components at once: meal containers, lids, coated cups, sealing film and flexible packs. Each component may have a different material structure, food type, contact time and temperature. A generic statement such as “food grade” is therefore not enough for a serious technical file.

The updated EU framework strengthens the information expected in declarations of compliance and supporting documentation. Buyers should pay particular attention to composition, non-intentionally added substances (NIAS), substances originating from waste streams, manufacturing quality controls and the test conditions used to demonstrate compliance. For repeated-use plastic articles, instructions should also help users slow deterioration, recognise observable changes and understand when the article should no longer be used.

Three product applications that need application-specific evidence

1. Heat-seal film for food trays

A custom BOPP heat-seal film roll should be evaluated as part of the complete sealing system. Buyers should define the tray material, sealing temperature, contact food, storage condition and expected shelf life. Film thickness alone does not establish suitability.

2. Polypropylene airline meal containers

For a PP airline meal container with a clear lid, the base and lid should be documented separately where their resin, additives or intended temperature ranges differ. The test programme should reflect the actual use case, including hot filling, reheating, chilled storage or fatty foods where applicable.

3. PLA-coated paper cups

A PLA-coated paper cup combines a paper substrate, coating, inks and potentially adhesives. Procurement teams should confirm which layer provides the food-contact surface and request documentation that matches the final printed construction and intended hot- or cold-drink use.

Six checks for purchase orders placed after the transition

Confirm the first market-placement date and batch status. Do not assume that old inventory and newly produced goods follow the same transition route.
Lock the complete material structure. Record resin or coating type, thickness, colour masterbatch, inks, adhesives and any recycled-content claim.
Request the current declaration of compliance. The document should identify the supplied article, applicable legislation, restrictions and intended conditions of use.
Match migration testing to real service conditions. Food simulant, temperature and contact time should be technically relevant to the buyer’s application.
Review NIAS and change control. Ask how raw-material, formulation and process changes are assessed and communicated.
Maintain traceability. Link samples, approvals, production batches, test reports and shipping documents so that the compliance file can be reconstructed.

What buyers should send in an RFQ

A useful RFQ states the destination market, food type, maximum contact temperature and time, single-use or repeated-use status, printing requirements, dimensions, annual volume and required documentation. These details allow the supplier to select an appropriate construction and propose a relevant validation plan. XHANCO does not treat one certificate as blanket approval for every market or application; documentation should be reviewed against the final specification and destination requirements.

For support matching materials, specifications and testing documents to an airline or foodservice programme, contact XHANCO with the intended use and target market.

EU Food-Contact Plastics: What Changed After the 16 September 2026 Transition Deadline