The Dutch Ministry of Health, Welfare, and Sport's State Secretary issued an order in November, 2025, modifying the Commodities Act's packaging material and article rules. The amendment entails changing some technical criteria and adding additional compounds to Appendix A of the regulations.
Important Changes
1. Revision of Plastic Recycling Rules
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Regulation (EC) No 282/2008 (repealed) was the previous reference.
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Regulation (EU) 2022/1616 (released September 15, 2022) about the safety criteria for recycled plastic materials in contact with food is the new reference.
2. Modifications to Particular Migration Limits (SML)
The migration limits (unit: mg/kg) for several metals and chemicals in Table 4.3 of Chapter 4 have been updated by the amendment:
|
Substance |
Previous Limit |
New Limit |
|
Copper |
5 |
4 |
|
Lithium |
0.6 |
0.048 |
|
Manganese |
0.6 |
1.8 |
|
Vanadium |
0.05 |
0.01 |
|
Arsenic |
0.01 |
0.002 |
|
Cadmium |
0.01 |
0.005 |
|
Cobalt |
0.05 |
0.02 |
|
Chromium |
0.1 |
0.25 |
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. Modifications Concerning Coating Materials
Adipinezuurdihydrazide (CAS 1071-93-8)
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Prior use: Not for direct food contact; only as a cross-linking agent for acrylic copolymers.
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New restriction: Coatings that come into close touch with acidic foods are prohibited.
Recently added material: Aziridine and 1,6-hexamethylene diisocyanate homopolymer, capped with butyl glycidyl ether and monomethoxy polyethylene glycol (CAS 2416007-57-1)
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Use: As an adhesive for coatings
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Limit: 0.05 mg/kg overall
On November 26, 2025, the Dutch Government Gazette issued the order, which became operative the following day.
