What Are The EU Market Access Requirements For PVC Cling Film And Aluminum Foil?
Oct 09, 2026
For importers and distributors of food packaging targeting the EU market, understanding EU regulations on food contact materials is essential for ensuring smooth customs clearance. As key consumables in the food service and supermarket sectors, PVC cling film and aluminum foil are subject to separate EU regulations governing plastics and metals, respectively, with distinct compliance requirements. Dongguan Juyou Paper And Plastic Products Co., Ltd. has been deeply engaged in the EU export market for many years and has established a comprehensive compliance production system. This article analyzes the EU market access standards and key procurement compliance points for these two product categories.

The EU employs a two-tier regulatory system for food contact materials, consisting of "framework regulations + specific material regulations." The top-level Regulation (EC) No. 1935/2004 establishes general safety principles: materials must not migrate harmful substances into food, must not alter the composition or flavor of food, and must ensure full supply-chain traceability. Plastic materials are subject to Commission Regulation (EU) No. 10/2011, which specifies the list of permitted substances and migration limits; metal materials must comply with general requirements and meet heavy metal migration limits. All products exported to the EU must be accompanied by a Declaration of Conformity issued by the manufacturer, along with third-party test reports, to clear customs.

PVC food wrap is a key focus area for compliance management among plastic food contact materials. At the raw material level, only monomers and additives listed on the EU Authorization List may be used; non-compliant plasticizers are prohibited, and residual levels of vinyl chloride monomer must be strictly controlled.
Regarding migration levels, the total migration must not exceed 10 mg/dm². Migration levels of heavy metals such as lead, cadmium, and mercury must comply with established limits, and the material must also meet migration standards under different temperatures and with various food simulants. In recent years, the EU has continuously tightened controls on substances of concern, such as microplastics and primary aromatic amines. Juyou's PVC food wrap utilizes food-grade, compliant formulations, has passed standard migration tests, and meets EU market access requirements.

Aluminum foil is classified as a metallic food contact material, with the key regulatory focus on heavy metal migration and hygiene performance. According to the general requirements of EU regulations, the migration of aluminum from aluminum foil into food must not exceed 1 mg/kg, and harmful heavy metals such as lead, cadmium, and arsenic must be strictly controlled to trace levels. Food-grade aluminum foil must also meet requirements for surface cleanliness and the absence of harmful residues, and additives used in the rolling process must comply with food contact safety standards. For aluminum foil used in high-temperature baking applications, migration stability at high temperatures must also be evaluated. Dongguan Juyou Paper And Plastic Products uses high-purity primary aluminum raw materials to produce aluminum foil, ensuring that impurity content, pinhole density, and surface cleanliness all meet the required standards.

When procuring EU-compliant products, three core principles must be followed: prioritize source factories with experience in compliant production and request complete declarations of conformity and test reports; clearly define the applicable food types and temperature ranges for the products to avoid risks associated with misuse; and verify that the product's traceability system is robust to ensure end-to-end traceability. Dongguan Juyou Paper And Plastic Products can provide customers with a full set of compliance support documents, including declarations of conformity and food contact safety test reports, and supports customized testing. The factory has simultaneously established a compliant raw material supply chain and production control system to ensure products consistently meet EU regulations, helping customers expand into the EU market.
In summary, the EU's regulatory framework for food contact materials is comprehensive and continuously updated; exporters must ensure compliance across the entire chain-from raw materials to production and testing. Partnering with source manufacturers that possess compliance capabilities is the optimal approach to reducing compliance risks and ensuring efficient customs clearance. Dongguan Juyou Paper and Plastic Products will continue to monitor updates to EU regulations and, through a standardized, compliant production system, provide high-quality PVC cling film, aluminum foil, and PE cling film products to customers worldwide.







