The EU has a harmonized legal framework, Regulation (EC) No 1935/2004, which sets out the general principles of safety and inertness for food contact materials (FCMs) – but it is not the whole story. Many materials, including paper and board, glass, wood, metals and textiles, have no specific EU-level requirements, and EU member states remain free to apply their own national legislation. Non-EU European countries add a further layer of national rules, many influenced by EU legislation but implemented with variations.
We help you navigate this multi-layered landscape, providing testing and compliance support aligned to the specific EU regulations, Council of Europe guidance and national requirements that apply to your products across Europe.
Meet food contact material requirements across Europe
We enable you to:
- Meet EU harmonized requirementsComply with Regulation (EC) No 1935/2004 and the material-specific EU regulations that apply to your products.
- Navigate non-harmonized materialsAccess guidance aligned to Council of Europe resolutions and technical guides where no EU-level regulation exists.
- Address broader chemical regulationsMeet requirements under REACH, POPs and packaging waste regulations that apply alongside FCM-specific law.
- Comply with national legislationNavigate member state and non-EU European requirements that complement or extend EU rules.
- Test with confidenceAccess full-range FCM testing, including migration and safety testing.
Core EU legislation for FCMs
Regulation (EC) No 1935/2004 is the EU's harmonized legal framework, setting out general principles of good manufacturing practice, safety and inertness for food contact materials. There is no single regulation covering all FCMs; different forms of material and specific substances are covered by their own harmonized regulations.
- Directive 84/500/EEC – Ceramics
- Directive 93/11/EEC – Release of N-nitrosamines and N-nitrosatable substances from elastomer or rubber teats and soothers
- Directive 2007/42/EC – Regenerated cellulose film
- Regulation (EC) No. 1895/2005 – Restriction of the use of certain epoxy derivatives
- Regulation (EC) No. 450/2009 – Active and intelligent materials
- Regulation (EU) No. 10/2011 – Plastics
- Regulation (EU) No. 284/2011 – Conditions and procedures for the import of polyamide and melamine plastic kitchenware originating or consigned from People’s Republic of China and Hong Kong
- Regulation (EU) No. 2024/3190 – Bisphenol A (BPA) and other bisphenols and bisphenol derivatives with harmonized classification for specific hazardous properties
- Regulation (EU) No. 2022/1616 – Recycled plastics
Resolutions and technical guides for other materials
Materials such as paper and board, glass, wood, cork, metals and alloys, textiles, adhesives, ion-exchange resins, printing inks, silicones, varnishes, coatings and wax have no specific EU-level requirements. The Council of Europe/European Directorate for the Quality of Medicines and Healthcare (EDQM) has developed resolutions and technical guides to close this gap. While not legally binding, these are widely accepted as guidance in the absence of EU or national legislation.
| Material Category | Reference / Guideline |
|---|---|
| Coatings | Resolution ResAP (2004) 1 |
| Cork materials | Cork Materials and Articles for Contact with Food – a technical guide for manufacturers and regulators |
| Glass | Guidelines for Lead Leaching from Glass Tableware |
| Inks | Resolution ResAP (2005) 2 |
| Ion exchange and adsorbent resins | Resolution ResAP (2004) 3 |
| Metals and alloys | Metals and alloys used in food contact materials and articles – a technical guide for manufacturers and regulators |
| Paper and board | Paper and board used in food contact materials and articles |
| Plastic colorants | Resolution AP (89) 1 |
| Plastic polymerization aids | Resolution AP (92) 2 |
| Rubber | Resolution ResAP (2004) 4 |
| Silicones | Resolution ResAP (2004) 5 |
Other applicable EU legislation
FCMs must comply not only with legislation, but also with broader chemical regulations that govern substances in general.
- Regulation (EC) No. 1907/2006 ‘REACH’
- Regulation (EU) No. 2019/1021 ‘Persistent organic pollutants (POPs)’
- Regulation (EU) No. 2025/40 ‘Packaging and packaging waste regulation (PPWR)’
Compliance across these legal regimes helps safeguard consumer health and the environment.
EU Member States’ legislation
At the same time, member states are free to complement EU regulations with national legislation, if no EU regulation exists. Many apply national requirements for non-harmonized materials or additional requirements for materials already covered by EU law.
| Country | Legislation |
|---|---|
| Austria | BGBI Nr. 893/1993 and BGBI II Nr. 259/2006 ‘Ceramics, Enamels’ |
| Czech Republic | Decree No. 38/2011 Coll. ‘Hygiene requirements for FCMs and articles’ |
| Denmark | Order No. 681 of May 25, 2020 ‘FCMs and penal code of violation of related EU Acts’ |
| Finland | Decree 268/1992 ‘Soluble heavy metals in FCMs’ |
| France | DGCCRF Recommendations |
| Germany | BfR Recommendations |
| Italy | Ministerial Decree of March 21, 1973 ‘Hygiene regulations for packaging, containers, and utensils intended to come into contact with food or personal use substances’ |
| Luxembourg | Grand-Ducal Regulation of May 19, 2026 ‘Ceramics’ |
| Norway | Regulation No. 1381 of December 21, 1993 (FOR-1993-12-21-1381) ‘Regulations relating to materials and articles in contact with food (Food Contact Regulations)’ |
| Spain | Royal Decree 847/2011 ‘Polymeric materials’ |
| The Netherlands | Commodities Act (Regulation on packaging and consumer products) |
Without one single harmonized standard for all European countries, and since products are often marketed in more than one country, compliance can be a complex matter.
Non-EU/EEA European countries
Non-EU/EEA European countries have their own rules for FCMs and FCAs. Many of these are influenced by EU legislation, and they are implemented nationally with some variations.
| Country | Legislation |
|---|---|
| Albania |
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| Georgia |
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| Montenegro |
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| North Macedonia |
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| Switzerland |
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| Ukraine |
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| United Kingdom (UK) |
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From January 1, 2021, the UK has the responsibility to keep its Regulations on FCMs and FCAs up to date. For Northern Ireland, EU rules still apply (Windsor Framework).
FCMs must not alter the food or bring about any deterioration in its organoleptic characteristics. In simple terms, the FCM that touch food must not change it or endanger human health.
Why SGS?
As the world's leading testing, inspection and certification company, we provide extensive experience testing food contact materials and articles for markets around the globe, covering food safety, performance and fitness for use. Our technical experts deliver the full range of FCM testing, including migration and safety testing, along with guidance on emerging regulations and compliance documentation.
Our experience helps you meet the appropriate territorial regulations for food contact materials across Europe.