Germany Updates Food Contact Materials Rules For Bisphenol A And Recycled Plastics

Germany has amended its national framework for food contact materials, updating the Bedarfsgegenständeverordnung and related provisions that support enforcement for materials and articles intended to come into contact with food. The ordinance was published in the Federal Law Gazette on 29 December 2025 and enters into force the day after promulgation. While much of the text modernises cross references to EU rules, the practical signal for industry is clear: for regulated categories of food contact materials, market placement is increasingly tied to documentation that can be shown quickly during inspections and at border checks.

What Changes For Food Contact Materials

The ordinance links placing certain materials and articles on the market to the presence of a written declaration of compliance. In particular, it references EU rules on Bisphenol A and other bisphenols in specified food contact materials, as well as the EU regime for recycled plastic intended for food contact use. For packaging manufacturers and converters, this raises the bar on how declarations are managed across product lines, especially where complex multi layer structures or recycled content are involved. For brands, it increases the importance of being able to retrieve supplier declarations and demonstrate that packaging specifications have been validated against the applicable EU requirements.

Implications For Importers And Supply Chains

Importers and distributors may face greater scrutiny where documentation is missing or inconsistent, even if the underlying material specification is unchanged. The update also revises provisions on special import rules and administrative language requirements, reinforcing the expectation that operators maintain accessible, market ready records. Compliance teams should treat this as a prompt to review document flows: ensure declarations of compliance are current, match the exact material configuration supplied, and are retrievable at speed for audits. Where recycled plastic is used, confirm that supplier claims are supported by the right conformity statements and that traceability is in place from recycler to finished packaging.

Summary

Germany’s ordinance updates the national rulebook for food contact materials to align with evolving EU requirements, with a practical emphasis on written declarations of compliance for certain bisphenol related materials and recycled plastics. For manufacturers, importers and brands, the key task is to tighten documentation control so that market placement and inspections are not delayed by gaps in compliance evidence.