Background
In December 2020, the Directorate General for Health and Food Safety (DG Sante) of the European Commission laid out a roadmap for the revision of the EU rules on food contact materials (FCMs; FPF reported). Initially planned for 2022, the revision has repeatedly been delayed. After a public consultation held in 2022, the Commission identified key pillars of the planned revision (FPF reported). Regarding the safety and sustainability of FCMs, these pillars were:
- Redress focus onto final material
- Prioritization of substances
- Supporting more sustainable alternatives
After publishing supporting studies on citizen engagement and information exchange, compliance, and enforcement, the Commission has most recently published a study in November 2025 on sustainability in the context of FCMs.
Current FCM revision status
Currently, Regulation (EC) No 1935/2004 provides a harmonized EU legal framework for food contact materials (FCMs). It sets out general safety requirements to ensure that materials do not endanger human health and establishes procedures for safety assessments of substances used in FCMs.
However, the European Commission identified significant issues with this existing approach, including the listing of authorized substances and risk assessment approaches, information flow and compliance along the supply chain, and coherence with other EU legislation, including the Packaging and Packaging Waste Regulation, published in 2025 (FPF reported).
Additionally, in an adopted resolution from October 6, 2016, the European Parliament states that “the current paradigm for evaluation of safety of FCMs is insufficient, as there is a general underestimation of the role of FCMs in food contamination and a lack of information on human exposure” (FPF reported).
New study on sustainability
The study was carried out for DG Sante by consulting firm ICF and aimed “to elaborate a definition of sustainability for the FCM context, review and assess the existing legislation affecting the FCM sector, map out the current FCM market and recent commercial and technical developments, and on that basis propose potential measures that could improve the sustainability of FCMs.” The publication of the report comes after multiple workshops with European stakeholders coordinated by ICF to identify gaps, available resources, and review potential policy measures.
Definition of sustainable FCMs
The report includes a comprehensive definition of what constitutes a sustainable FCM: “Food Contact Materials (FCMs) contribute to sustainable development when they meet current needs of ensuring security of food supply and keeping food safe without compromising the ability of future generations to meet their needs. Safeguarding the ability of future generations to meet their needs is approximated to staying within planetary boundaries.” In addition, it stresses the avoidance of preventable waste, aligned with the waste hierarchy, and the need for “transformative change across all life cycle stages […] to achieve necessary functionality, maximum circularity and minimum negative impacts on public health and the environment.”
Finally, the proposed definition of sustainable FCMs in the report addresses not only impacts of the FCMs and their use, but also what kind of food products are being produced or packaged using an FCM, stating that “FCMs contribute to the transition to a sustainable food system and a circular economy. They do so by […] facilitating the transition to healthier and more sustainable diets.” To achieve sustainable FCMs, the definition highlights the need for “policy and business decisions [to] be based on science-based indicators and targets,” the latter requiring further development.
The report identifies seven severe sustainability problems with FCMs:
- Plastic pollution and human exposure to synthetic chemicals
- Multi-materials cannot be recycled
- Most FCMs are not designed for recycling
- Most FCMs are made with primary (virgin) materials
- Single use far exceeds reuse
- FCMs use “pervasive chemicals” that are a long-term public health threat (As defined in the report: “Pervasive chemicals are substances that are widely used and can be found throughout various products and environments. These chemicals can persist in the environment and may have long-term impacts on health and ecosystems.”)
- The potential for FCMs to contribute to the transition to a more sustainable food system remains
Conclusions and next steps
Data collected during the development of the report “has confirmed that there is a need for FCM-specific measures on sustainability.” Problems identified with current FCMs could be addressed (to an extent) through existing EU policies, including legislation on packaging, eco-design, and single-use plastics, as well as private initiatives. However, the authors identify a number of unaddressed gaps and opportunities that could be best addressed via future FCM legislation. The report prioritizes a set of four policy measures with high potential to improve sustainability across the FCM sector and that could be integrated into the planned revision of EU FCM legislation:
- Harmonized standards and guidance for reusable FCMs: Ensuring that reusable items meet stringent safety and durability criteria.
- Eco-design guidance for FCMs: Integrating circularity, resource efficiency, and chemical safety at design stage.
- Product essentiality test: Ensuring that materials and chemicals used are truly necessary and aligned with sustainability goals.
- Sector-wide science-based sustainability targets: Creating measurable goals for pollution prevention, resource use, chemical safety, and circularity.
Under the recommendation to develop eco-design guidance for FCMs, one of the
opportunities outlined is the use of open-source data and structured guidance to reduce knowledge and resource gaps. The study explains that companies adopting such a structured approach to eco-design decisions “could differentiate themselves through sustainable innovation and increased consumer trust.” To support this recommendation, the study suggests leveraging existing LCA tools and cites the UP Scorecard as one potential resource.
References
European Commission (2025). “Study on sustainability in the context of food contact materials (FCM) in view of a possible revision of the FCM legislation.” DOI: 10.2875/3789818
European Commission (December 2025). “Revision of EU Rules.”
This article was originally published by the Food Packaging Forum and has been adapted for the UP Scorecard.
