On 19 December 2025, the European Commission (EC) published the final study examining how sustainability could be better integrated into the European Union’s food-contact materials (FCMs) legislation [1]. The study forms part of the preparatory work supporting the ongoing revision of the EU FCM regulatory framework. Its primary objective is to explore how sustainability can be embedded into FCM legislation without compromising core objectives such as food safety, food security, and food waste prevention. FCMs considered in the study were packaging, kitchenware, cookware, tableware, home disposables (e.g., cling film), and industrial food processing and food storage equipment.

The report defines sustainability in FCMs in line with the broader concept of sustainable development. According to the study, sustainable FCMs must support the secure supply and safety of food today while minimizing environmental and health impacts, preventing non-essential waste, and enabling circularity across the materials’ life cycle. In that context, the report identifies seven FCM sustainability concerns, which are listed below. 

1. FCMs contribute to the accumulation of synthetic materials and chemicals in the natural and human environments.
2. FCMs use multi-materials, composite materials, and additives.
3. Most FCMs are not being designed or redesigned to achieve sustainability.
4. The production of FCMs uses principally virgin materials.
5. There is a significant use of single-use FCMs.
6. FCMs use pervasive chemicals.
7. The potential for FCMs to contribute to the transition to a more sustainable food system remains unaddressed.

At the same time, the study emphasizes that any revision of FCM legislation should avoid overlap with other EU policy instruments, such as the Ecodesign Regulation, the Packaging and Packaging Waste Regulation (PPWR), and the Single-Use Plastics Directive (SUPD). Instead, the analysis focuses on sustainability issues that are specific to FCM legislation.

The study initially identified 31 potential measures to improve the sustainability of FCMs. These were subsequently narrowed down to nine and ultimately to four final measures. These four measures are considered feasible, non-duplicative of existing legislation, and potentially suitable for inclusion in a future impact assessment accompanying the revision of the FCM rules. The four proposed measures are:

1. Harmonized standards and guidance for reusable FCMs, to include standardized product cleaning/handling, traceability, and labeling guidance, would provide greater consistency and safety. The report further notes that clear requirements and guidance on durability, handling/cleaning, traceability and reusability cycles of materials would remove barriers that may prevent businesses from choosing to use reusable FCMs.
2. Eco-design guidance for FCMs would help ensure that they are developed with sustainability, functionality, and safety in mind. In addition, to make eco-design principles widely accessible, a dedicated EU digital platform would be developed to host the guidance, share best practices, and provide sustainability assessment tools.
3. A product essentiality test would evaluate whether problematic FCMs serve a critical purpose and, if they do, whether there are more sustainable alternatives that provide the same level of safety, durability, or usability.
4. Sector-wide science-based targets would achieve long-term improvements in FCM sustainability. They would be developed using environmental impact assessments, material performance benchmarks, and EU sustainability goals, to ensure a structured approach to emissions reduction, material efficiency, and waste prevention.

The report concludes by stating that, “FCM design choices are complex, therefore seeking to make FCM production and consumption more sustainable is a balancing act and trade-offs are, at the present stage of technological development, unavoidable.” It further notes that this complexity is “not well addressed in the current or forthcoming legislation” but adds that many of the gaps identified in the study would be “best addressed in other policies than FCM legislation.” 

[1] A copy of the report, titled, “Study on sustainability in the context of food contact materials (FCM) in view of a possible revision of the FCM legislation,” can be accessed from the EU website.