The European Union maintains some of the world's strictest food safety regulations, and for dried fruit exporters, understanding food contact material compliance is no longer optional—it's a market access requirement. The regulatory landscape is undergoing significant changes in 2026, with multiple deadlines that directly impact packaging suppliers and food exporters alike.
The Core Framework: Regulation (EC) No 1935/2004 remains the foundational legislation governing all food contact materials in the EU [1]. This regulation establishes general safety requirements mandating that materials must not transfer constituents to food in quantities that could endanger human health or alter food composition unacceptably. However, this framework regulation is supported by specific measures for different material types, and here's where complexity arises: only four material categories have harmonized EU-wide rules (ceramics, regenerated cellulose, active/intelligent materials, and plastics). Paper, cardboard, adhesives, inks, and coatings—the very materials commonly used in dried fruit packaging—fall under national legislation of individual member states, creating a patchwork of requirements that suppliers must navigate carefully.
PFAS Restrictions: The August 2026 Deadline. Per- and polyfluoroalkyl substances (PFAS) have been widely used in food packaging for their grease and moisture resistance properties. However, growing evidence of health risks has triggered comprehensive restrictions. Under PPWR, food-contact packaging must meet three concentration thresholds: individual PFAS compounds cannot exceed 25 parts per billion (ppb), the sum of all individually restricted PFAS cannot exceed 250 ppb, and total fluorine content (as a proxy for all PFAS) cannot exceed 50 parts per million (ppm) [2][3]. For dried fruit packaging, this particularly affects grease-resistant papers, moisture barrier coatings, and certain adhesive systems. Suppliers using conventional grease-resistant treatments must transition to PFAS-free alternatives such as plant-based coatings, silicone barriers, or physical barrier structures.
The new EU Packaging Regulation applies from 12 August 2026. Companies must prepare for significant changes including packaging waste reduction targets, mandatory recycled content requirements (10-35% from 2030 depending on packaging type), harmonized labeling with pictograms, and producer registration obligations. Online marketplaces must verify producer compliance before allowing products to be sold in the EU [6].
Documentation Requirements: Declaration of Compliance (DoC). Every food contact material placed on the EU market must be accompanied by a written Declaration of Compliance confirming that the product meets applicable regulations [2][3]. This document must be maintained for five years and made available to competent authorities upon request. For dried fruit exporters, this means your packaging supplier must provide DoC documentation, and you must retain these records as part of your food safety management system. Migration testing—demonstrating that substances do not transfer from packaging to food beyond specified limits—is often required to support DoC claims, particularly for new materials or when changing suppliers.
Extended Producer Responsibility (EPR) adds another layer of complexity. In Germany, the strictest enforcement jurisdiction, EPR registration is required from the first parcel shipped to German consumers [5]. The Lucid registration system requires producers to report packaging volumes and pay licensing fees, with the license number (LUCID-ID) printed on each package. Austria requires annual registration fees of €300 plus €150 per material category. France has similar requirements but enforcement for small volumes remains inconsistent. For Southeast Asian exporters selling directly to EU consumers or through EU distributors, understanding these obligations is critical to avoid customs delays and penalties.
