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EU food contact materials: declaration of compliance, migration limits, BPA ban

Anything sold in the EU that is meant to touch food, from plastic containers and bottles to cookware, cups and packaging, is a food contact material. It must not release its constituents into food at harmful levels or change the food unacceptably, it must be made under good manufacturing practice, and plastics need a written declaration of compliance. Since 20 July 2026, most articles containing bisphenol A can no longer be placed on the EU market for the first time.

Checked against official sources: 2026-10

At a glance

FrameworkRegulation (EC) No 1935/2004: applies to all food contact materials, with labelling and traceability rules
Good manufacturing practiceRegulation (EC) No 2023/2006
PlasticsRegulation (EU) No 10/2011
Overall migration limit10 mg per dm² of food contact surface; 60 mg per kg of food simulant for infant and young-child food
Generic specific migration limit60 mg/kg where Annex I sets no specific limit
Declaration of complianceWritten declaration required for plastics at every marketing stage except retail (Annex IV content)
Bisphenol A banRegulation (EU) 2024/3190, in force since 20 January 2025; most final articles could be first placed on the market only until 20 July 2026
Materials covered by the BPA banAdhesives, rubbers, ion-exchange resins, plastics, printing inks, silicones, varnishes and coatings

The general EU rules for all food contact materials

Regulation (EC) No 1935/2004 is the framework for every material and article intended to come into contact with food. Materials must not release their constituents into food at levels harmful to human health, or change the food's composition, taste and odour in an unacceptable way. The framework also sets rules on labelling, by an indication for use or the appropriate symbol, and on compliance documentation and traceability. Regulation (EC) No 2023/2006 on good manufacturing practice makes sure the manufacturing process is well controlled.

On top of the framework, some materials have specific EU measures. Where there are none, EU countries may keep or adopt their own national rules under Article 6 of Regulation 1935/2004, so an exporter of, for example, metal or glass articles also checks the rules of the country where the goods will be sold.

Specific EU measures by material

Plastics and the bisphenol A ban

Plastic food contact materials must not transfer more than 10 milligrams of total constituents per dm² of food contact surface (60 milligrams per kg of food simulant for infant and young-child food), and individual substances must stay within the specific migration limits in Annex I, or a generic 60 mg/kg where none is set. At every marketing stage other than retail, the business operator provides a written declaration of compliance with the information in Annex IV, and keeps supporting documents with the conditions and results of testing for the authorities.

Regulation (EU) 2024/3190 bans bisphenol A and other harmful bisphenols in adhesives, rubbers, ion-exchange resins, plastics, printing inks, silicones, varnishes and coatings for food contact. It entered into force on 20 January 2025. Most single-use and repeat-use final articles could be first placed on the market only until 20 July 2026; some, such as single-use articles for preserving fruit, vegetables or fishery products and professional food production equipment, until 20 January 2028. Repeat-use articles placed on the market under the general deadline may stay on the market until 20 July 2027.

Step by step

  1. Identify every material that touches food in your product: plastic, coating, rubber, silicone, ink, adhesive, ceramic or metal.
  2. Check the specific EU measure for each material, or the national rules of the destination country where there is none.
  3. Test plastics against the overall and specific migration limits of Regulation (EU) No 10/2011.
  4. Issue a written declaration of compliance for plastics and keep the test reports as supporting documents.
  5. Confirm that no food contact layer contains bisphenol A or other banned bisphenols, and label the goods for food contact use.

Documents you usually need

Common problems and how to avoid them

The EU buyer asks for a declaration of compliance and you only have a test report.

What to do: Issue a written declaration of compliance with the Annex IV information, and keep the test report as supporting documentation.

A can coating or bottle contains bisphenol A.

What to do: Switch to a bisphenol-free material; most final articles containing BPA could be first placed on the EU market only until 20 July 2026.

A silicone or metal product has no specific EU measure.

What to do: Meet the framework Regulation (EC) No 1935/2004 and check the national rules of the EU country of sale.

The product is not labelled for food contact use.

What to do: Add the indication for use or the food contact symbol, as the framework regulation requires.

Sources

  1. Food contact materials: Legislation European Commission, DG SANTE
  2. Commission Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food EUR-Lex
  3. Commission Regulation (EU) 2024/3190 on bisphenol A and other bisphenols (consolidated text, 23 February 2026) EUR-Lex
  4. Commission adopts ban of Bisphenol A in food contact materials European Commission, DG SANTE

Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.

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Common questions

What is a food contact material?

Any material or article intended to come into contact with food, such as containers, bottles, cookware, tableware, utensils and packaging.

What is the EU declaration of compliance for plastics?

A written declaration required under Regulation (EU) No 10/2011 at every marketing stage except retail, with the information listed in Annex IV.

What is the overall migration limit for plastics in the EU?

10 mg of total constituents per dm² of food contact surface, or 60 mg per kg of food simulant for infant and young-child food.

When does the EU ban on BPA in food contact materials apply?

Regulation (EU) 2024/3190 entered into force on 20 January 2025; most final articles could be first placed on the market until 20 July 2026, and some until 20 January 2028.

Are there EU rules for metal or glass food contact articles?

They fall under the framework Regulation (EC) No 1935/2004; where no specific EU measure exists, EU countries may apply national rules.

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