Food contact – bisphenol A and plastics

The European Commission has published two regulations clarifying the application of the regulation on plastics in contact with food.

Regulation (EU) 2026/250 corrects the framework on bisphenol A and clarifies how the already approved restriction applies, including its impact on marketing and transitional periods. The regulation specifies the practical scope of the restriction and its effects on the market. https://www.boe.es/buscar/doc.php?id=DOUE-L-2026-80139

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Regulation (EU) 2026/245 updates the list of authorized substances for food plastics, incorporating new substances and adjusting the conditions of use of other existing substances. These amendments require companies to review formulations, technical documentation and declarations of compliance. https://www.boe.es/buscar/doc.php?id=DOUE-L-2026-80138

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Packaging – Regulation (EU) 2025/40 (PPWR)

The European Commission has circulated internally a draft interpretative “Commission Notice” on Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), the final text of which is expected before the Regulation’s implementation date of 12 August 2026.

The Interpretive Notice aims to explain how PPWR should be applied in practice and, in particular:

• Clarify what is considered “packaging”.
• How the figures of “manufacturer” and “producer” should be understood and how their responsibilities are shared within the value chain, including certain obligations such as the use of QR codes on reusable packaging.
• Addresses the application of PFAS restrictions on food contact packaging.