Montenegro introduces EU-aligned requirements for food contact materials (FCMs) and articles.
In June 2026, Montenegro issued the Regulation on Materials and Articles Intended to Come into Contact with Food (Official Gazette of Montenegro (OGM) No. 91/2026, ‘the Framework Regulation’). This new law transposed European Regulation (EC) No. 1935/2004 on food contact materials (FCMs) and articles (consolidated version to March 2021 for reference) into Montenegro’s domestic law, aligning the country’s regulatory framework more closely with EU requirements.
What does this regulation require?
Key provisions in the Framework Regulation include:
- Establishing general safety requirements for FCMs and articles, including active and intelligent materials and articles
- Requiring FCMs to be manufactured in compliance with good manufacturing practice (GMP) requirements
- Specifying that specific measures may be adopted for FCMs described in Annex 1 of the regulation (see Table 1 below), including but not limited to: a) positive lists of authorized substances, b) specific and overall migration limits (SMLs and OMLs), c) purity criteria, d) testing methods and sampling rules, e) traceability and f) labeling requirements, including the use of the phrase ‘za kontakt sa hranom’ (‘for food contact’), a specific indication as to their use (e.g. coffee machine, wine bottle or soup spoon), or the ‘glass and fork’ symbol shown in Annex 2 of the regulation for FCMs and articles not already in contact with food when placed on the market
- Authorizing the competent authority to prescribe additional specific requirements for FCMs listed in Annex 1 of the regulation
- Stipulating requirements for a declaration of compliance (DoC)
- Specifying administrative penalties for non-compliance by individuals and businesses
| Item | FCM | Item | FCM |
|---|---|---|---|
| 1 | Active and intelligent materials and articles | 10 | Plastics |
| 2 | Adhesives | 11 | Printing inks |
| 3 | Ceramics | 12 | Regenerated cellulose |
| 4 | Cork | 13 | Silicones |
| 5 | Rubber | 14 | Textiles |
| 6 | Glass | 15 | Varnishes and coatings |
| 7 | Ion-exchange resins | 16 | Waxes |
| 8 | Metals and alloys | 17 | Wood |
| 9 | Paper and board |
Table 1. List of groups of materials and articles that may be subject to specific measures as per Annex 1 of OGM No.91/2026
Who is impacted?
The new law affects stakeholders across the FCM supply chain, including manufacturers, importers, retailers and other intermediaries operating in Montenegro.
When does it apply?
The Framework Regulation became effective on July 7, 2026, and repealed the previous regulation on materials and articles intended to come into contact with food and may be placed on the market (OGM No. 80/2016).
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