On November 18, 2025, the State Secretary of the Dutch Ministry of Health, Welfare, and Sport issued an order amending the regulations on packaging materials and articles under the Commodities Act. The revision involves adding new substances to Appendix A of the regulations and adjusting certain technical requirements.
Key Amendments
1. Update to Plastic Recycling Regulations
- Previous reference: Regulation (EC) No 282/2008 (repealed)
- New reference: Regulation (EU) 2022/1616 (issued September 15, 2022) regarding safety requirements for recycled plastic materials in contact with food.
2. Adjustments to Specific Migration Limits (SML)
The amendment revises the migration limits (unit: mg/kg) for several metals/chemical substances in Table 4.3 of Chapter 4:
|
Substance |
Previous Limit |
New Limit |
|
Arsenic |
0.01 |
0.002 |
|
Cadmium |
0.01 |
0.005 |
|
Chromium |
0.1 |
0.25 |
|
Cobalt |
0.05 |
0.02 |
|
Copper |
5 |
4 |
|
Lithium |
0.6 |
0.048 |
|
Manganese |
0.6 |
1.8 |
|
Vanadium |
0.05 |
0.01 |
3. Newly Added Substances and Their Limits:
|
Substance |
Limit (mg/kg) |
|
Barium |
1.2 |
|
Beryllium |
0.01 |
|
Iron |
40 |
|
Mercury |
0.003 |
|
Molybdenum |
0.12 |
|
Thallium |
0.0001 |
|
Tin |
100 (unless otherwise specified in EU 2023/915) |
|
Silver |
0.08 |
4. Revisions Related to Coating Substances
Adipinezuurdihydrazide (CAS 1071-93-8)
- Previous use: Limited to cross-linking agent for acrylic copolymers, not for direct food contact.
- New restriction: Not permitted in coatings that come into direct contact with acidic foods.
Newly added substance: Reaction product: homopolymer of aziridine and 1,6-hexamethylene diisocyanate, capped with butyl glycidyl ether and monomethoxy polyethylene glycol (CAS 2416007-57-1)
- Use: As a coating adhesive
- Limit: 0.05 mg/kg (total)
The order was published in the Dutch Government Gazette on November 26, 2025, and took effect the day after its publication.
Further Information
