The EU has recently amended its ‘Food Contact Plastics’ Regulation. This latest revision will become effective on January 31, 2019.

SAFEGUARDS | Hardlines NO. 010/19

SafeGuardS orig pint milk containers


On January 11, 2019, the European Union (EU) published Regulation (EU) 2019/37 [1] to revise Regulation (EU) 10/2011 on Food Contact Plastics. The latest publication contains, inter alia, the following:



  • Replacing four substances and adding three completely new substances to the Union list of authorized substances (Table 1 to Annex I)
  • Adding one completely new entry for a group restriction of three substances. These are to be expressed as crotonic acid (Table 2 to Annex I)
  • Replacing the specification for 3-hydroxybutanoic acid-3-hydroxypentanoic acid, copolymer (FCM substance no. 744) with a specific migration limit for crotonic acid
  • Replacing two rows on the use of food simulants for certain foods (Table 3 to Point 4 of Annex III, see Table 1 below) 

The latest Regulation will become effective on January 31, 2019 (date of entry into force).

According to the latest Regulation, food contact plastics that are compliant before the effective date of the latest publication may be placed on the market until January 31, 2019 and may remain on the market until stocks are exhausted. 

Highlights on the use of simulants for certain food types in Table 3 under Point 4 to Annex III of Regulation (EU) 2019/37 and a comparison with existing rules are summarized in Table 1. 

Rows 3 and 4 to Table 3 of Point 4 under Annex III ‘Food Simulant Assignment for Demonstrating Compliance with the Overall Migration Limit’
Regulation (EU) 2019/37 amending Regulation (EU) 10/2011 Regulation (EU 10/2011
(amended by Regulation (EU) 2017/752)
Scope Food Contact Plastics Food Contact Plastics
Food simulant to be used for food type 50% ethanol for aqueous and alcoholic food and milk products with a pH ≥ 4.5 50% ethanol for aqueous and alcoholic food and milk products
3% acetic acid and 50% ethanol for aqueous and alcoholic food and milk products with a pH < 4.5 3% acetic acid and 50% ethanol for aqueous, acidic and alcoholic food and milk products
Effective date January 31, 2019 In force

Table 1.

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. From overall migration test to expert advices on emerging regulations and compliance issues and documentation review, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

Next step:

Stakeholders are advised to comply with the latest requirements for food contact plastics for the EU market.

For enquiries, please contact:

Hingwo Tsang
Global Information and Innovation Manager
t: +852 2774 7420

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