The Netherlands Modifies Law on Food Contact Materials

SafeGuardSHardgoodsDecember 02, 2025

SG 176/25

The Netherlands has revised its Commodities Act on food contact materials (FCMs) and articles.

On November 26, 2025, the State Secretary for Health, Welfare and Sport of the Netherlands issued an amendment (reference number 4274094-1090928-WJZ), revising requirements for FCMs and articles under the Commodities Act (Regulation on Packaging and Consumer Products) (‘the Regulation’).

The revision replaces Regulation (EC) No 282/2008 with Regulation (EU) 2022/1616 for food contact recycled plastics (SafeGuards 167/25) and updates several specifications for metals and coatings.

Key changes to the Regulation are summarized in Table 1.

Section to Part A of Annex to the Regulation	Highlight of change
Chapter IV ‘Metal’ § 4.3 ‘Requirements for finished product’	Revises specific migration limits (SMLs) for several substances: 0.002 mg/kg arsenic (from 0.01 mg/kg) 0.005 mg/kg cadmium (from 0.01 mg/kg) 0.25 mg/kg chromium (from 0.1 mg/kg) 0.02 mg/kg cobalt (from 0.05 mg/kg) 4 mg/kg copper (from 5 mg/kg) 0.048 mg/kg total lithium compounds (as lithium, from 0.6 mg/kg) 1.8 mg/kg manganese (from 0.6 mg/kg) 0.01mg/kg vanadium (from 0.05 mg/kg) Introduces SMLs for several chemicals: 1.2 mg/kg barium 0.01mg/kg beryllium 40 mg/kg iron 0.003 mg/kg mercury 0.12 mg/kg molybdenum 0.0001mg/kg thallium 100 mg/kg tin (unless otherwise stated in Regulation (EU) 2023/915) 0.08 mg/kg silver
Chapter X ‘Coatings’ § 3 ‘Dispersions of macromolecular substances in water’	Revises specification for adipic acid dihydrazine to ‘Not to be used in coatings in direct contact with acidic foods’
Chapter X ‘Coatings’ § 12.3 ‘Requirements for final product’	≤ 5 mg/kg adipic acid dihydrazine (SML, from 0.05 mg/kg)

Section to Part A of Annex to the Regulation

Highlight of change

Chapter IV ‘Metal’
§ 4.3 ‘Requirements for finished product’

Revises specific migration limits (SMLs) for several substances:
- 0.002 mg/kg arsenic (from 0.01 mg/kg)
- 0.005 mg/kg cadmium (from 0.01 mg/kg)
- 0.25 mg/kg chromium (from 0.1 mg/kg)
- 0.02 mg/kg cobalt (from 0.05 mg/kg)
- 4 mg/kg copper (from 5 mg/kg)
- 0.048 mg/kg total lithium compounds (as lithium, from 0.6 mg/kg)
- 1.8 mg/kg manganese (from 0.6 mg/kg)
- 0.01mg/kg vanadium (from 0.05 mg/kg)

Introduces SMLs for several chemicals:
- 1.2 mg/kg barium
- 0.01mg/kg beryllium
- 40 mg/kg iron
- 0.003 mg/kg mercury
- 0.12 mg/kg molybdenum
- 0.0001mg/kg thallium
- 100 mg/kg tin (unless otherwise stated in Regulation (EU) 2023/915)
- 0.08 mg/kg silver

Chapter X ‘Coatings’
§ 3 ‘Dispersions of macromolecular substances in water’

Revises specification for adipic acid dihydrazine to ‘Not to be used in coatings in direct contact with acidic foods’

Chapter X ‘Coatings’
§ 12.3 ‘Requirements for final product’

≤ 5 mg/kg adipic acid dihydrazine (SML, from 0.05 mg/kg)

Table 1

This amendment entered into force on November 26, 2025, and applies retroactively from July 1, 2025.

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