SG 129/26
Serbia introduces new regulation for food contact materials and articles.
In August 2026, Serbia published a new regulation on food contact materials (FCM) and articles. It also applies to certain products for infants and children under three years of age, including those used for feeding, sucking, soothing and sleeping, as well as food packaging and other articles of general use (‘the Regulation,’ Official Gazette of Serbia (OGS) No 73/2026-31).
The Regulation incorporates domestic requirements and provisions from several pieces of EU legislation relating to FCMs and articles:
- Directive 78/142/EEC on vinyl chloride monomer (VCM, current consolidated version to February 1978 for reference)
- Directive 84/500/EEC on ceramics (current consolidated version to May 2026 for reference)
- Directive 93/11/EEC on the release of N-nitrosamines and N-nitrosatable substances from elastomer or rubber teats and soothers
- Directive 2007/42/EC on regenerated cellulose films
- Regulation (EC) No 1935/2004 on FCM and articles (current consolidated version to March 2021 for reference)
- Regulation (EC) No. 1895/2005 on certain epoxy derivatives (current consolidated version to November 2005 for reference)
- Regulation (EC) No. 450/2009 on active and intelligent materials and articles
- Regulation (EU) No. 10/2011 on food contact plastics (current consolidated version to July 2026 for reference)
- Regulation (EU) No. 284/2011 on specific conditions and detailed procedures for the import of polyamide and melamine plastic kitchen ware originating in or consigned from China and Hong Kong
- Regulation (EU) 2024/3190 on bisphenol A (BPA) and other phenols and bisphenol derivatives with harmonized classification for specific hazardous properties in certain FCM and articles (current consolidated version to February 2026 for reference)
What does this regulation require?
Key provisions in OGS No 73/2026-31 include:
- Establishing:
- General requirements for all FCM and articles
- Material-specific rules for certain FCM and articles: a) plastics, b) active and intelligent materials and articles, c) ceramics, and d) regenerated cellulose films
- Rules governing a) epoxy derivatives, b) N-nitrosamines and N-nitrosatable substances, c) vinyl chloride monomer, d) bisphenols, and e) FCM and articles for drinking water
- National requirements for specific groups of FCM and articles
- Specifying that the scope of application applies to:
- Substance-specific provisions for BPA, its salts and hazardous bisphenols and hazardous bisphenol derivatives for the manufacture of the following FCM and articles: a) adhesives, b) rubber, c) ion-exchange resins, d) plastics, e) printing inks, f) silicones, and g) varnishes and coatings
- Material-specific rules for a) clay, b) glass, c) enamels, d) metals and alloys, e) wood and cork, including cork closures, f) paper and cardboard, g) silicones, h) rubber, i) ion-exchange resins, j) textiles, k) biomaterials, l) bamboo, and m) mixtures in the manufacture of FCM and articles (adhesives, dyes, printing inks, varnishes, and coating and waxes)
- Exempting a) antiques and b) covering or coating materials, such as those covering cheese rinds, prepared meat products or fruits, which form an integral part of food and may be consumed together with that food
- Requiring FCM to be manufactured in compliance with good manufacturing practice (GMP)
- Permitting targeted measures to be adopted for 17 groups of FCM and articles listed in Annex 1 of the Regulation, including but not limited to: a) positive list of authorized substances, b) purity standards, c) specific and overall migration limits (SMLs and OMLs), and d) rules for sampling, testing methods, compliance, traceability and documentation
- Providing that additional measures will be applied to food contact recycled materials and articles
- Defining requirements for a declaration and labeling, including the use of the phrase ‘за контакт са храном’ (‘for food contact’) and a specific indication as to their use (e.g. coffee machine, wine bottle or soup spoon) or the ‘glass and fork’ symbol in Annex 2 of the Regulation
- Establishing specific requirements for certain FCM and articles, including:
- Plastics, including a) the Union list of approved substances and their specifications, b) substances not on the Union List (non-intentionally added substances (NIAS), polymerization aids and BPA, and other hazardous bisphenols and hazardous bisphenol derivatives), c) plastic multilayer materials and articles, d) multi-layered materials, and e) articles composed of several different materials
- Conditions and procedures for the import of plastic kitchenware made of polyamide and melamine originating or consigned from China and Hong Kong
- Active and intelligent materials and articles, regenerated cellulose films, certain epoxy derivatives, as well as FCM and articles containing VCM
- Migration of N-nitrosamines and N-nitrosatable substances from elastomer or rubber bottle teats and soothers
- The use of BPA, other bisphenols and bisphenol derivatives with harmonized classification for specific hazardous properties in certain FCM and articles
- FCM and articles for drinking water
- National requirements for clay, glass, metals and alloys (see Tables 1 and 2 below), wood and cork, paper and cardboard, silicones, rubber, textiles, biomaterials, bamboo, ion-exchange resins, enameled materials and articles, as well as mixtures used in the manufacture of FCM and articles (adhesives, dyes, printing inks, varnishes and coatings, and waxes)
- Transitional measures for single-use and repeat use FCMs and articles manufactured with BPA:
- Single-use FCM and articles manufactured with BPA that are compliant with applicable rules before August 22, 2026, and which were placed on the market before July 20, 2026, may remain on the market until January 20, 2028
- Repeat-use FCM and articles manufactured with BPA that are compliant with applicable rules before August 22, 2026, and which were placed on the market before July 20, 2026, may remain on the market until July 20, 2027
- Repeat-use FCM and articles manufactured with BPA used as professional food production equipment that are compliant with applicable rules before August 22, 2026, may be placed on the market until January 20, 2028, and remain on the market until January 20, 2029, at the latest
- 26 Annexes to support the implementation of the Regulation, including but not limited to positive lists of substances for plastics and regenerated cellulose films, simulants, conformity testing, rules for determining the migration of specified substances and additional requirements for metals and alloys, paper and cardboard, silicones and rubber materials
| Entry | SML Requirement | Entry | SML Requirement |
|---|---|---|---|
| 1 | ≤ 5 mg/kg aluminum (Al) | 8 | ≤ 0.12 mg/kg molybdenum (Mo) |
| 2 | ≤ 0.04 mg/kg antimony (Sb) | 9 | ≤ 14 mg/kg nickel (Ni) |
| 3 | ≤ 1 mg/kg chromium (III) | 10 | ≤ 0.08 mg/kg silver (Ag), otherwise ≤ 0.4 mg/kg Ag for silver and silver-plated tableware and accessories |
| 4 | ≤ 0.02 mg/kg cobalt (Co) | 11 | ≤ 100 mg/kg tin (Sn) |
| 5 | ≤ 4 mg/kg copper (Cu) | 12 | ≤ 5 mg/kg zinc (Zn) |
| 6 | ≤ 40 mg/kg iron (Fe) | 13 | ≤ 2 mg/kg zirconium (Zr) |
| 7 | ≤ 0.55 mg/kg manganese (Mn) |
Table 1. SMLs for elements used as components of metals and alloys
| Entry | SML Requirement | Entry | SML Requirement |
|---|---|---|---|
| 1 | ≤ 0.002 mg/kg arsenic (As) | 5 | ≤ 0.010 mg/kg lead (Pb) |
| 2 | ≤ 1.2 mg/kg barium (Ba) | 6 | ≤ 0.048 mg/kg lithium (Li) |
| 3 | ≤ 0.01 mg/kg beryllium (Be) | 7 | ≤ 0.003 mg/kg mercury (Hg) |
| 4 | ≤ 0.005 mg/kg cadmium (Cd) | 8 | ≤ 0.001 mg/kg thallium (Tl) |
Table 2. SMLs for elements present as contaminants or impurities in metals and alloys
Who is impacted?
The new law affects stakeholders across the FCM and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in Serbia.
When does it apply?
The Regulation became effective on August 22, 2026 (eight days after publication in the OGS). It simultaneously repealed Articles 4-83 of the Rulebook on the conditions regarding health safety of general use items that may be placed on the market (Official Gazette of the SFRY No 26/83, 61/84, 56/86, 50/89, 19/91, 60/2019 – other regulations, 78/2019 – other regulations and 78/19-other regulations)
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