(PPWR 1) Food Contact Compliant Packaging: The Complete Guide to the New European Requirements 2025

Géraldine Pierrot
Mar 15
3 min read

Regulation (EU) 2025/40 comes into effect and disrupts the rules for all food professionals. Decrypting the essential points to remain compliant.

A regulatory revolution to protect consumers

Since January 10, 2025, the European Union has imposed new strict rules concerning all materials and objects in contact with foodstuffs (MCDA). Whether you are a packaging manufacturer, distributor, or catering professional, these changes directly affect you.

Regulation 2025/40 replaces the old directives and finally harmonizes practices across Europe. The goal? To ensure that everything that touches our food is perfectly safe and traceable.

Who is concerned? The expanded scope

All actors in the chain are targeted (Article 1)

Manufacturers of materials and packaging
Food processors and packers
Distributors and importers
Restaurants and catering services
Retail businesses

The materials concerned include

Primary packaging (in direct contact)
Kitchen utensils and equipment
Storage and transport containers
Food films and wrapping papers
Seals, caps, and accessories

The new definitions that change everything (Article 2)

The regulation clarifies essential concepts:

"Food contact material": Any material or object intended to come into contact with foodstuffs, already in contact, or capable of transferring its constituents to food under normal conditions of use.

"Migration": The transfer of substances from the material to the food. The new limits are drastically reduced.

"Functional barrier": A layer that prevents the migration of substances. Its effectiveness must now be scientifically proven.

Strengthened general safety requirements (Article 3)

Basic principle: total inertia

Materials must not:

✗ Pose a danger to human health

✗ Cause an unacceptable change in the composition of food

✗ Alter organoleptic properties (taste, smell, appearance)

Novelty 2025: The preventive approach

Manufacturers must now prove safety BEFORE placing on the market. Gone are the days of discovering problems after the fact!

Concretely, this means:

Tests de migration obligatoires
Évaluation des risques documentée
Certificats de conformité pour chaque lot
Surveillance continue post-commercialisation

Labeling:

More transparency for users (Article 4)

The new mandatory symbol

The "glass and fork" pictogram becomes mandatory on all marketed MCDA. It must be:

Visible and indelible
At least 5mm in height
Accompanied by specific mentions if necessary

Mandatory mentions

Each product must indicate:

"For food contact" or the regulatory symbol
Conditions of use (temperatures, durations, types of food)
The name and address of the manufacturer
A batch number for traceability
Possible restrictions ("Do not use in microwave", "For dry foods only")

Special cases

For materials sold in bulk or professional equipment, the information may appear on accompanying documents but must remain accessible at all times.

Good manufacturing practices (GMP) become mandatory (Article 5)

A certified quality system

All manufacturers must now:

Implement a documented quality assurance system
Train their staff on specific risks
Conduct checks at each stage
Keep records for a minimum of 5 years

Critical control points

The regulation identifies key steps:

Receipt of raw materials: verification of certificates
Production: compliance with process temperatures and times
Storage: conditions preventing any contamination
Shipping: maintaining product integrity

What changes concretely for your company

For manufacturers

Invest in regular migration tests
Update all technical documentation
Train teams on new standards
Revise labeling before the end of 2025

For professional users

Require certificates of conformity
Check the labeling of all your containers
Train staff in good practices
Document compliant use

For distributors

Control supplier documentation
Ensure complete traceability
Remove non-compliant products
Inform customers of the new rules

Deadlines to meet

Compliance schedule:

Immediate: New products placed on the market
July 1, 2025: Existing stocks at manufacturers
December 31, 2025: End of marketing of old products
June 30, 2026: Final market withdrawal

Our advice for a successful transition

Audit all your current MCDA
Contact your suppliers to obtain certificates
Plan the necessary changes
Train your teams now
Document everything for inspections

In Conclusion

Regulation 2025/40 marks a turning point in European food safety. While the requirements are stricter, they ensure better consumer protection and a welcome harmonization of practices.

Do not wait to comply: Authorities have announced increased inspections from the second half of 2025.

Keywords

food contact materials, MCDA regulation 2025, compliant food packaging, EU regulation 2025/40, food safety, packaging traceability, European food standards