The Netherlands published Regulation amending the Commodities Act Regulation on Packaging and Consumer Goods

Vol. 1502 | 11 Dec 2025

The Netherlands updated food-contact rules by revising metal specific migration limits and adding new coated-material restrictions and SMLs, effective 27 November 2025 for packaging and consumer goods in contact with food.

On 26 November 2025, The Ministry of Health, Welfare and Sport of the Netherlands published the Regulation amending the Commodities Act Regulation on Packaging and Consumer Goods concerning materials and articles intended to come into contact with food on the Government Gazette (Staatscourant 2025, 40221).

The following are the highlight of the amendments:

Requirements for metal in Chapter IV

The updates of the specific migration limit (SML) aligned with the technical guide of “metals and alloys used in food contact materials and articles” which is published by the European Directorate for the Quality of Medicines & HealthCare (EDQM).

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 Chapter X

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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