Correction of EU Food Contact Materials Regulation: What Manufacturers and Distributors Must Review

Key data

If your company manufactures, imports or distributes packaging, utensils or any material that comes into contact with food, this correction affects you directly. The Regulation (EU) 2024/1735 —the European framework regulation on food contact materials— has been subject to a correction of errors published on 3 September 2026 under reference CELEX:32024R1735R(04).

The correction does not introduce new substantive obligations, but it does modify technical and linguistic provisions whose incorrect wording could generate divergent interpretations between Member States. In a sector where traceability and compliance documentation are frequently audited, working with an outdated text is a real risk.

What does this regulation establish?

This correction of errors acts on Regulation (EU) 2024/1735, which is the European regulation governing all materials and objects intended to come into contact with food: packaging, wrapping, kitchen utensils, food processing machinery, films, caps, trays and any other object that may transfer substances to food.

The type of corrections introduced are of a technical and linguistic nature. This means that:

• Drafting errors that could lead to incorrect or contradictory interpretations are corrected.
• Terms or references that were not consistent with the rest of the regulation text are unified.
• No substantive obligations for companies are added or removed.
• The objective is to ensure the correct interpretation and uniform application of the regulation in all EU Member States.

It is important to understand that, although this is a correction of errors, the corrected text is the legally valid text from its publication. Any internal procedure, technical sheet or declaration of conformity that cites or reproduces provisions of Regulation (EU) 2024/1735 must be based on the corrected version.

Economic and operational impact

As it does not modify the substantive regulatory framework, this correction does not generate new direct costs for product or process adaptation. However, it does have a real operational impact in the following areas:

• Compliance documentation: Declarations of conformity, technical sheets and regulatory files that cite Regulation (EU) 2024/1735 must be reviewed to ensure they reflect the corrected text.
• Internal procedures: Quality and regulatory procedures that reference specific provisions of the regulation must be updated.
• Audits and certifications: In an inspection or audit, working with an outdated text may generate observations or non-conformities, even if substantive compliance is correct.
• Supply chain communication: Manufacturers supplying large food operators or retailers may receive requests for documentary updates from their customers.

The real cost to the company will depend on the volume of affected documentation and the complexity of its regulatory procedures. For companies with well-structured compliance management systems, the effort will be limited. For those with scattered or outdated documentation, it may require a more thorough review.

Who does it affect?

This correction is relevant to any company whose activities are regulated by Regulation (EU) 2024/1735. Specifically:

• Manufacturers of food packaging and wrapping (plastic, glass, metal, paper, cardboard, composite materials).
• Manufacturers of kitchen utensils, tableware and kitchenware in contact with food.
• Manufacturers of food processing machinery and equipment.
• Distributors and importers of food contact materials.
• Food sector companies that manufacture or package their own products and manage the conformity of their contact materials.
• Quality, regulatory and legal departments of all the above companies.
• Consultancies and advisors specializing in food regulation and packaging.

Practical example

A plastic packaging manufacturer for dairy products has in its quality management system a procedure for preparing declarations of conformity that cites specific articles of Regulation (EU) 2024/1735.

Following the publication of the correction CELEX:32024R1735R(04) on 3 September 2026, the regulatory manager must:

1. Download the corrected consolidated text of Regulation (EU) 2024/1735 from EUR-Lex.
2. Compare the provisions cited in its procedures and declarations with the corrected text.
3. If any reference or textual citation has changed, update the affected documentation.
4. Record the review in the management system to leave traceability in case of a possible audit.

If the company has customers that are large food retail chains, these are likely to request the updated version of the declarations of conformity in their next supplier review. Anticipating this avoids delays in supplier approval.

What should companies do now?

1. Download the corrected text: Access EUR-Lex and obtain the updated version of Regulation (EU) 2024/1735 that incorporates the correction CELEX:32024R1735R(04), published on 3 September 2026.
2. Review compliance documentation: Identify all declarations of conformity, technical sheets and regulatory files that cite provisions of the regulation and verify that the text is consistent with the corrected version.
3. Update internal procedures: Quality and regulatory departments must review their operating procedures that reference articles or annexes of the regulation.
4. Inform the supply chain: Communicate to relevant customers and suppliers that the documentation has been reviewed in accordance with the corrected text, especially if declarations of conformity are issued to third parties.
5. Record the review: Leave documentary evidence of the review carried out, with date and responsible person, to ensure traceability in internal or external audits.
6. Consult with the legal or regulatory area: If any of the technical corrections affects provisions that the company applies in a specific way, assess with specialized advice whether any additional action is necessary.

Official source

Consult the complete regulation in the official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32024R1735R(04)