The Netherlands Revises Law on Food Contact Materials

SafeGuardSHardgoodsJul 31, 2025

SG 111/25

The Netherlands has amended its Commodities Act (Regulation on Packaging and Consumer Products) on food contact materials and articles (Warenwetregeling verpakkingen en gebruiksartikelen).

In June 2025, the Netherlands issued Regulation of the State Secretary for Health, Welfare and Sport of June 12, 2025, reference number 4131373-1083806-WJZ (the amendment) to revise the requirements for food contact materials (FCM) and articles under the nation’s Commodities Act (Regulation on Packaging and Consumer Products) (‘the Regulation’, version valid from July 1, 2025 to present).

The amendment revises several chapters in Part A of the Annex to the Regulation by:

Revising the use of substances and their specifications, including those for phthalates and metals
Aligning the specific migration limit (SML) for some substances with those in Regulation (EU) No. 10/2011 on food contact plastics (current consolidated version to March 2025)
Making some technical amendments and corrections, including but not limited to revising the term ‘butyl benzyl phthalate, containing not more than 1% dibenzyl phthalate’ to ‘benzyl butyl phthalate, containing not more than 1% dibenzyl phthalate’

Highlights of key changes in the amendment are summarized in Table 1.

Chapter/Section under Part A of Annex to the Regulation	Highlight of change
Chapter 0, § 0.5.1, Part e ‘Specific migration requirements’	Clarifies that the release of primary aromatic amines (PAA) from materials and articles made from aromatic isocyanates or dyes prepared by diazo coupling must comply with the requirements under Section 2 of Annex II to Regulation (EU) No 10/2011 on food contact plastics
Chapter I ‘Plastics’ Table I-1	Strengthens SML for DIBP: ≤ 0.6 mg/kg (from 1 mg/kg) and group restriction (9)¹
Chapter II ‘Paper and board’ §1.3.3	Strengthens SML for bisphenol A (BPA): ≤ 0.05 mg/kg (from 0.6 mg/kg) Introduces an SML requirement for DBP: ≤ 0.6 mg/kg¹ Revises SML for three phthalates: ≤ 0.6 mg/kg¹ for each of DBP, DEHP and DIBP
Chapter II ‘Paper and board’ § 1.3.5	Clarifies that the release of PAA from materials and articles made from aromatic isocyanates or dyes prepared by diazo coupling must comply with the requirements under Section 2 of Annex II to Regulation (EU) No 10/2011 on food contact
Chapter II ‘Paper and cardboard for hot use (as cooking packaging and for filtering beverages at temperatures higher than 80 °C’ § 2.3.2 and § 2.3.4	Replaces SML for ‘aromatic amines: NA’’ with ‘PAA: ND (Not detected), expressed as aniline, detection limit (DL) = 0.002 mg/kg) in § 2.3.2 § 2.3.4 clarifies that the release of PAA from materials and articles made from aromatic isocyanates or dyes prepared by diazo coupling must comply with the requirements under Section 2 of Annex II to Regulation (EU) No 10/2011 on food contact
Chapter III ‘Rubber products’ § 4.2	Revises SML for two phthalates: ≤ 0.6 mg/kg¹ for each of DBP and DEHP
Chapter III ‘Rubber products’ § 5.7 -Table’	Replaces SML requirements for ‘aromatic amines’ with those for ‘PAA’
Chapter III ‘Rubber products’ § 5.9	Clarifies that the release of PAA from materials and articles made from aromatic isocyanates or dyes prepared by diazo coupling must comply with the requirements under Section 2 of Annex II to Regulation (EU) No 10/2011 on food contact plastics
Chapter IV ‘Metal’ § 2.2, Part g, 4° ‘Plasticizers’	Replaces the term ‘diisodecyl phthalate’ with ‘phthalic acid, diesters with primary saturated C_9-11 alcohols with more than 90% C₁₀ (CAS Nos 68515-49-1 and 26761-40-0)’
Chapter IV ‘Metal’ § 4.3	Revises table of substances, their SML values and footnotes, including but not limited to: ≤ 0.01 mg/kg arsenic (from 0.002 mg/kg) ≤ 0.05 mg/kg BPA (from 0.6 mg/kg) ≤ 0.6 mg/kg BBP, with footnote 2¹ ≤ 0.01 mg/kg cadmium (from 0.005 mg/kg) ≤ 0.1 mg/kg chromium (from 0.25 mg/kg) ≤ 0.6 mg/kg DBP (from 0.3 mg/kg), with footnote 2¹ ≤ 0.6 mg/kg DEHP (from 1.5 mg/kg), with footnote 2¹ ≤ 1.8 mg/kg phthalic acid, diesters with primary saturated C_9-11 alcohols with more than 90% C₁₀ (from 15 mg/kg DIDP) ≤ 0.05 mg/kg cobalt (from 0.02 mg/kg) ≤ 5 mg/kg copper (from 4 mg/kg) ≤ 0.6 mg/kg total lithium compounds (as lithium, from 0.048 mg/kg) ≤ 0.6 mg/kg manganese (from 1.8 mg/kg) ≤ 0.05 mg/kg vanadium (from 0.01 mg/kg) New entry for PAA
Chapter IX ‘Wood and cork’ § 3.2	Revises table of substances, their SML values and footnotes, including: ≤ 0.6 mg/kg DBP (from 0.3 mg/kg), with footnote 2¹ ≤ 0.6 mg/kg DEHP (from 1.5 mg/kg), with footnote 2¹ Replaces ‘aromatic amines’ with ‘PAA (ND, expressed as aniline, DL = 0.002 mg/kg)’
Chapter IX ‘Wood and cork’ § 3.4	Clarifies that the release of PAA from materials and articles made from aromatic isocyanates or dyes prepared by diazo coupling must comply with the requirements under Section 2 of Annex II to Regulation (EU) No 10/2011 on food contact plastics
Chapter X ‘Coatings § 12.3	Revises table of substances, their SML values and footnotes, including but not limited to: ≤ 0.6 mg/kg BBP, with footnote 5¹ ≤ 0.1 mg/kg chromium compounds (as chromium) ≤ 0.6 mg/kg DBP, with footnote 5¹ (from 0.3 mg/kg, alone or with DIBP) ≤ 0.6 mg/kg DEHP with footnote 5¹ ≤ 0.6 mg/kg DIBP, with footnote 5¹ (from 0.3 mg/kg, alone or with DBP)
Chapter X ‘Coatings § 12.6	Clarifies that the release of PAA from materials and articles made from aromatic isocyanates or dyes prepared by diazo coupling must comply with the requirements under Section 2 of Annex II to Regulation (EU) No 10/2011 on food contact plastics
Chapter XII ‘Epoxy polymers’ § 2 ‘Table XII-1 Excipients’	Revises table of substances, their SML values and footnotes, including: ≤ 0.6 mg/kg DBP, with footnotes (1) and (2)¹ (from 0.3 mg/kg, with footnote (1)) ≤ 0.6 mg/kg DEHP, with footnotes (1) and (2)¹ (from 1.5 mg/kg, with footnote (1))
¹The SML applies to the sum of DBP, DIBP, BBP and DEHP, expressed as DEHP equivalents using the formula: DBP5 + DIBP4 + BBP 0.1 + DEHP1

Table 1

The amendment entered into force on July 1, 2025.

Packaging and consumer goods that comply with the Regulation before the entry into force of this amendment, and which were placed on the market before January 1, 2026, may remain on the market until stocks are exhausted.

Abbreviations

Item	Abbreviation	Name	Item	Abbreviation	Name
1	BBP	Benzyl butyl phthalate	4	DIBP	Di-isobutyl phthalate
2	DBP	Dibutyl phthalate	5	DIDP	Diisodecyl phthalate
3	DEHP	Di(2-ethylhexyl) phthalate

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