The European Commission recently published Regulation (EU) 2025/2240, an amendment that brings important news for manufacturers of plastic materials and articles that use salicylic acid or untreated wood flour and wood fibres. This regulation is an amendment to Regulation (EU) No 2023/1442 and extends the transitional measures previously introduced, allowing certain products to remain on the market for longer.
The background to this is that Regulation (EU) 2023/1442 amended EU legislation on plastics in contact with food (Regulation (EU) No 10/2011) by removing the generic authorisation that previously allowed the use of 'wood flour and fibres, untreated' (FCM No 96). This amendment reflects the EFSA's position that wood and plant materials are not inherently inert and must be assessed on a case-by-case basis. Salicylic acid was also removed from the positive list because, in view of EFSA's re-evaluation, there was insufficient data available to confirm that its use remained safe without defining a specific migration limit or restrictions on use.
Transitional measures were put in place at the time to give the industry sufficient time to adapt. However, this transitional period proved to be too short: many companies had difficulty submitting their dossiers in full and in accordance with the new requirements, particularly when it came to natural materials such as wood fibres.
With the new regulation, the EU is extending the transitional period until 31 January 2026. Plastic materials and articles containing these substances may therefore continue to be placed on the market during this period, provided that an application for assessment has been submitted in good time. Once that application has been validated, the products may even continue to circulate until the European Commission takes a final decision.
For producers, this means a respite: the extra time allows them to collect the necessary data, supplement it and obtain formal approval. At the same time, the EU emphasises that this extension is not an end point but a temporary solution. The final assessment of these substances remains necessary, so the market should continue to prepare for possible future changes.
For the sector, this is an important signal that the EU understands the practical challenges involved in assessing complex or natural materials, without compromising food safety. Companies working with these substances would do well to use the extra time efficiently and get their authorisation dossiers fully in order.
The message is clear: the rules are becoming stricter, but the EU is giving the industry the chance to adapt in a controlled and achievable way.
IBE BVI members can request the text of this regulation here
