Netherlands - Approved Amendments to the Commodities Act Regulations on Packaging and Consumer Goods Concerning Food Contact Materials and Articles

On November 18, 2025, The Ministry of Health, Welfare and Sport of the Netherlands approved the Regulation amending the Commodities Act Regulation on Packaging and Consumer Goods about materials and articles intended to come into contact with food.

The following are the highlight of the amendments:

Requirements for metal

The specific migration limit (SML) for the following substance is updated:

Substance	SML (mg/kg)
Arsenic	0.002
Cadmium	0.005
Chromium	0.25
Cobalt	0.02
Copper	4
Lithium compounds	0.048 (as lithium)
Manganese	1.8
Vanadium	0.01

The following substances with corresponding SML are added:

Substance	SML (mg/kg)
Barium	1.2
Beryllium	0.01
Iron	40
Mercury	0.003
Molybdenum	0.12
Thallium	0.0001
Tin	100
Silver	0.08

Requirements for coatings

In section 3(a):

• adipic acid dihydrazide are not to be used in coatings in direct contact with acidic foods.
• reaction products of propyleneimine with 1,6-diisocyanato-hexane homopolymer, blocked with butyl glycidyl ether and monomethoxy polyethylene glycol is added.

In section 7(c), reaction products of propyleneimine with 1,6-diisocyanato-hexane homopolymer, blocked with butyl glycidyl ether and monomethoxy polyethylene glycol is added.

In section 12.3:

• SML of adipic acid dihydrazide is amended to 5 mg/kg.
• SML of reaction products of propyleneimine with 1,6-diisocyanato-hexane homopolymer, blocked with butyl glycidyl ether and monomethoxy polyethylene glycol is added, which is 0.05 mg/kg.

Effective date

The regulations have entered into force on 27 November 2025.

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