Food packaging adhesives need application-specific evidence. Check EU plastic packaging transition dates, supplier declarations and migration files for 2026.
Confirm which plastic packaging materials rely on the transition in Regulation (EU) 2025/351, obtain current adhesive food contact information, and connect both to the intended use of the final pack and migration assessment. A polymer data sheet alone cannot establish that the finished food package complies.
Food packaging adhesives and the September 2026 transition
Before approving an order, converters and buyers need to check whether the evidence from the supplier covers the planned packaging. Article 4 of Commission Regulation (EU) 2025/351 sets two transition conditions worth checking:
- Plastic materials and articles that comply with the previous version of Regulation (EU) No 10/2011 and other relevant Union legislation, and were first placed on the market before 16 September 2026, may continue to be placed on the market until stocks are exhausted.
- For specified intermediate products or substances first placed on the market after 16 December 2025, the accompanying declaration of compliance must disclose reliance on the transition if they meet the old requirements but not the new ones. It must state that they can only be used to manufacture plastic materials and articles to be placed on the market before 16 September 2026.
Check the first placing-on-the-market record rather than relying on a manufacturing date or an undated stock list. The transition does not require every qualifying package already in the supply chain to be discarded on 16 September.
Which part applies to an adhesive layer?
The same regulation clarifies that the Chapter II compositional requirements for plastics do not apply to non-plastic layers such as adhesives, printing inks and coatings. That distinction does not remove the need to assess migration from the finished plastic article held together by adhesive. Treat the deadline as a reason to review the whole packaging file, not as a blanket requirement for every adhesive to carry a plastics declaration of compliance.
Three documents that answer different questions
A food contact status declaration is a statement from the adhesive supplier of the information and restrictions needed to assess its product for a specified food contact application. FEICA guidance published in March 2022 explains why adhesive suppliers provide adequate information to support compliance of the finished article. Its template is useful for reviewing the document; the 2026 transition dates come from the newer regulation.
| Document | What to check | What it cannot establish alone |
|---|---|---|
| Plastics declaration of compliance | Product identity, applicable legislation, restrictions and any transition statement relevant to the supplied plastic material or intermediate. | Suitability of every adhesive formulation or every finished packaging construction. |
| Adhesive food contact status information | Supplier and product identity, issue date, intended applications, substances requiring consideration and use limitations. | Compliance of a finished pack under conditions outside the stated assessment. |
| Final packaging assessment | Actual construction, food type, contact time and temperature, migration evidence and any necessary sensory evaluation. | Approval of a changed construction, formulation or use condition without review. |
Migration is the transfer of substances from a food contact material into food. Non-intentionally added substances, or NIAS, include impurities, reaction intermediates and decomposition or reaction products. The amended Annex IV of the plastics regulation requires adequate information about NIAS when their presence could cause the final material to fail the safety requirements of the framework regulation. A generic statement such as food grade gives the buyer too little information to evaluate those conditions.
A supplier checklist for the next packaging order
Use these questions to review supplier files before a repeat order or material substitution. They put the regulation and FEICA guidance into a purchasing checklist.
- Identify the exact product and document revision. Match the supplier name, adhesive grade, plastic material reference and relevant batch or order records.
- Describe the pack. Send the layer construction, adhesive position, coating amount and any claimed barrier. Identify whether the application is a label, a seal or another bonded structure.
- Specify the food and use conditions. Include food type, storage period, contact temperature and any heating or freezing conditions. Ask whether the existing assessment covers that combination.
- Request the relevant substance information. Ask what restrictions, migration limits, NIAS findings or other limitations the downstream assessor needs. Agree on a confidential technical exchange if needed.
- Record the transition basis. For material relying on Article 4, obtain the applicable declaration wording and records supporting the first placing-on-the-market date. Assign a person to resolve missing or conflicting dates.
- Define what requires another review. Include changes to the adhesive formula, raw material supplier, substrate, coating amount, barrier or intended use. Keep the approval tied to the construction actually assessed.
FEICA places the final assessment with the manufacturer of the finished food contact material or article, using its intended conditions of use. Ask the laboratory or regulatory reviewer to define a suitable assessment plan. An adhesive test report without its sample construction and test conditions is difficult to apply to a different pack.
What to send with an SIS packaging adhesive inquiry
The Jusage packaging application page and SIS Series provide starting points for material discussion. SIS means styrene-isoprene-styrene. For a food packaging project, send the formulation route, substrate, processing conditions, required bond performance and food contact documentation request together.
A technical data sheet supports grade screening. Food contact suitability needs evidence for the specific material, complete adhesive formulation and final use. A product family page does not establish a food contact approval. Use the grade recommendation service to discuss the technical brief and the documents to request.
FAQ: food packaging adhesive documentation
Does every adhesive need an EU plastics declaration of compliance?
No. FEICA distinguishes adhesive food contact status information from the declaration required for materials covered by the plastics regulation. Ask for adequate information for the intended use of the adhesive, and have the responsible reviewer confirm the rules for the actual packaging construction and destination market.
Can old plastic packaging stock be sold after 16 September 2026?
Article 4(1) allows qualifying plastic materials and articles first placed on the market before that date to continue until stocks are exhausted. They must meet the previous plastics requirements and other relevant Union legislation. Keep evidence of those conditions; the manufacturing date alone does not establish eligibility.
Does a raw polymer data sheet prove the final adhesive is suitable?
No. It describes the polymer for technical screening. Information from the adhesive supplier and the final packaging assessment must cover the formulation, construction and intended use. Request those records before treating a grade change as approved for an existing food packaging order.
Prepare the grade and documentation brief
For food packaging adhesives, start with the actual pack and the evidence the converter needs. Send Jusage your application and document requirements to discuss grade direction and technical files. Include the destination market, food type, layer construction, processing conditions and planned order date.