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2026-03-21

Regulation

Regulation (EU) 2025/351: Key Changes for Plastic FCM

A practical reading of Regulation (EU) 2025/351, with a focus on NIAS, labeling updates, transition timing and what plastic-packaging suppliers need to review first.

Regulation (EU) 2025/351 matters because it pushes plastic food-contact compliance further into process control, not just end-stage testing. The update brings more attention to NIAS, labeling logic and how plastic packaging is assessed across the full production chain.

For many suppliers, the first mistake is to read the regulation only as a legal text and not as an operating change. Once NIAS expectations tighten, the relevant question is no longer just whether intentionally added substances are known. It is whether the business understands what else may be created, carried over or released through processing.

That has consequences for documentation, formulation review and supplier communication. It also affects how businesses think about transition timing. A transition period does not remove the need to prepare early. It usually means the preparation window is already open.

The companies under the most pressure are those with plastic formats that depend on older assumptions, limited process visibility or incomplete supporting files. For them, the safest move is to identify which materials and lines need closer review first and not treat all plastic packaging as equally exposed.

In practice, the regulation is a reminder that plastic FCM compliance is becoming harder to manage through isolated tests alone. It now depends more heavily on process understanding, file discipline and upstream control.

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