On May 20, 2020, the European Commission (EC) published its Farm to Fork Strategy, which is described as “a new comprehensive approach to how Europeans value food sustainability.” Specifically, in regards to food packaging, the EC announced that it will revise the current legislation on food contact materials (FCMs) “to improve food safety and public health (in particular in reducing the use of hazardous chemicals), support the use of innovative and sustainable packaging solutions using environmentally-friendly, re-usable and recyclable materials, and contribute to food waste reduction.” It will further work on legislation to support re-use in food services to replace single-use food packaging and cutlery. A draft action plan within the document has scheduled a proposal of the revised legislation to be released in the fourth quarter of 2022.

The EU government’s initiative to consider revising the legislation began in 2016 when the European Parliament Committee on Environment, Public Health and Food Safety (ENVI) published a report finding that “the current paradigm for evaluation of safety of FCMs is insufficient” (FPF reported). In November 2017, the EC then published a roadmap “to assess whether the current EU legislative framework for FCMs is fit for purpose and delivers as expected” (FPF reported). It then held an initial (FPF reported) and follow-up (FPF reported) stakeholder event to inform stakeholders about the 12-month period in which the legislation would be evaluated using stakeholder input.

In March 2020, a group of international scientists led by the Food Packaging Forum published a scientific consensus statement on chemicals present in FCMs and current challenges within the EU legislation to properly address them (FPF reported).

The announcement to revise the FCM legislation has been welcomed by stakeholders such as Chem Trust, which has been advocating for improvements in the regulations. The organization’s director, Michael Warhurst, said “CHEM Trust welcomes the Farm to Fork strategy‘s clear commitment to improve the EU’s outdated and ineffective laws regulating chemicals in food contact materials like packaging and to reduce the use of hazardous substances. This revision is clearly needed in order to fulfill the Strategy’s objective of creating a ‘fair healthy and environmentally friendly food system’ as a central part of the European Green Deal.” He notes, however, that they are concerned about the “extended timeline for this work” considering that stakeholders have already been calling for improvements to these regulations for over the past six years.

Read more

EC (May 20, 2020). “Questions and Answers: Farm to Fork Strategy – building a healthy and fully sustainable food system.”

EC (May 20, 2020). “Factsheet: From farm to fork: Our food, our health, our planet, our future.”

EC (May 20, 2020). “Remarks delivered by Commissioner Kyriakides at the Press Conference on the adoption of the Biodiversity Strategy and the Farm to Fork Strategy.”

EC (May 20, 2020). “Remarks delivered by Commissioner Sinkevičius at the Press Conference on the adoption of the Biodiversity Strategy and the Farm to Fork Strategy.”

Sidsel Dyekjaer (May 20, 2020). “EU Commission announces revision of law on chemicals in Food Contact Materials.” ChemTrust

Clelia Oziel (May 21, 2020). “Commission pledges revision of EU FCM legislation by end-2022.” Chemical Watch

Keller and Heckman LLP (June 5, 2020). “EC Extends Timeline for Finalization of Any Proposal for Revision of FCM Legislation to the End of 2022.”


EC (May 20, 2020). “Communication from the Commision to the European Parliament, the Council, the European Economic and Social Committee, and the Committee of the Regions: A Farm to Form Strategy for a fair, healthy and environmentally-friendly food system.” (pdf)