Which rules apply to plastic cups and tumblers?

Limit 1 mg/kg (migration basis)

specific migration limit, Annex II Table 1

• Food-contact product
• Material: Plastic (type not stated) or Polypropylene (PP) or Polyethylene (PE) or Polycarbonate (PC) or PET or Polystyrene (PS) or ABS or Polyamide (nylon, PA) or PVC or Copolyester or Acrylic (PMMA) or Ethylene-vinyl acetate (EVA) or Fluoropolymer (PTFE, PFA, FEP) or Other plastic (not listed) or Melamine resin

Depends on: whether the product touches food, materials

In force since 3 Sep 2020

Applies to products placed on the market on or after 3 Sep 2020

Entry as listed in the consolidated text (version 2026-07-14). The law text does not state the application date of later amending acts, so the date used is the one the text supports: Annex II is marked M15 (Regulation (EU) 2020/1245, OJ 3.9.2020); the application date of that amendment is not stated in the consolidated text, so the OJ date is used and later amendments of individual entries are not traced.

Name

Aluminium

Salts allowed (Art. 6(3)(a))

yes

Specific migration limit (mg/kg food or food simulant)

1

Limit 0.02 mg/kg (migration basis)

specific migration limit, Annex II Table 1

• Food-contact product
• Material: Plastic (type not stated) or Polypropylene (PP) or Polyethylene (PE) or Polycarbonate (PC) or PET or Polystyrene (PS) or ABS or Polyamide (nylon, PA) or PVC or Copolyester or Acrylic (PMMA) or Ethylene-vinyl acetate (EVA) or Fluoropolymer (PTFE, PFA, FEP) or Other plastic (not listed) or Melamine resin

Depends on: whether the product touches food, materials

In force since 3 Sep 2020

Applies to products placed on the market on or after 3 Sep 2020

Entry as listed in the consolidated text (version 2026-07-14). The law text does not state the application date of later amending acts, so the date used is the one the text supports: Annex II is marked M15 (Regulation (EU) 2020/1245, OJ 3.9.2020); the application date of that amendment is not stated in the consolidated text, so the OJ date is used and later amendments of individual entries are not traced.

Name

Nickel

Salts allowed (Art. 6(3)(a))

no

Specific migration limit (mg/kg food or food simulant)

0,02

Limit 0.04 mg/kg (migration basis)

specific migration limit, Annex II Table 1; remark (2): SML might be exceeded at very high temperature

• Food-contact product
• Material: Plastic (type not stated) or Polypropylene (PP) or Polyethylene (PE) or Polycarbonate (PC) or PET or Polystyrene (PS) or ABS or Polyamide (nylon, PA) or PVC or Copolyester or Acrylic (PMMA) or Ethylene-vinyl acetate (EVA) or Fluoropolymer (PTFE, PFA, FEP) or Other plastic (not listed) or Melamine resin

Depends on: whether the product touches food, materials

In force since 3 Sep 2020

Applies to products placed on the market on or after 3 Sep 2020

Entry as listed in the consolidated text (version 2026-07-14). The law text does not state the application date of later amending acts, so the date used is the one the text supports: Annex II is marked M15 (Regulation (EU) 2020/1245, OJ 3.9.2020); the application date of that amendment is not stated in the consolidated text, so the OJ date is used and later amendments of individual entries are not traced.

Name

Antimony

Salts allowed (Art. 6(3)(a))

no

Specific migration limit (mg/kg food or food simulant)

0,04

Remark

(2)

Limit 5 mg/kg (migration basis)

specific migration limit, Annex II Table 1

• Food-contact product
• Material: Plastic (type not stated) or Polypropylene (PP) or Polyethylene (PE) or Polycarbonate (PC) or PET or Polystyrene (PS) or ABS or Polyamide (nylon, PA) or PVC or Copolyester or Acrylic (PMMA) or Ethylene-vinyl acetate (EVA) or Fluoropolymer (PTFE, PFA, FEP) or Other plastic (not listed) or Melamine resin

Depends on: whether the product touches food, materials

In force since 3 Sep 2020

Applies to products placed on the market on or after 3 Sep 2020

Entry as listed in the consolidated text (version 2026-07-14). The law text does not state the application date of later amending acts, so the date used is the one the text supports: Annex II is marked M15 (Regulation (EU) 2020/1245, OJ 3.9.2020); the application date of that amendment is not stated in the consolidated text, so the OJ date is used and later amendments of individual entries are not traced.

Name

Zinc

Salts allowed (Art. 6(3)(a))

yes

Specific migration limit (mg/kg food or food simulant)

5

Limit 0.05 mg/kg (migration basis)

sum of all lanthanide substances migrating to the food or food simulant

• Food-contact product
• Material: Plastic (type not stated) or Polypropylene (PP) or Polyethylene (PE) or Polycarbonate (PC) or PET or Polystyrene (PS) or ABS or Polyamide (nylon, PA) or PVC or Copolyester or Acrylic (PMMA) or Ethylene-vinyl acetate (EVA) or Fluoropolymer (PTFE, PFA, FEP) or Other plastic (not listed) or Melamine resin

Depends on: whether the product touches food, materials

In force since 3 Sep 2020

Applies to products placed on the market on or after 3 Sep 2020

Entry as listed in the consolidated text (version 2026-07-14). The law text does not state the application date of later amending acts, so the date used is the one the text supports: Annex II is marked M15 (Regulation (EU) 2020/1245, OJ 3.9.2020); the application date of that amendment is not stated in the consolidated text, so the OJ date is used and later amendments of individual entries are not traced.

17 rules from Commission Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food

Limit 0 mg/kg (migration basis)

• Food-contact product
• Material: Plastic (type not stated) or Melamine resin

Depends on: whether the product touches food, materials

Dates run from 1 May 2011 to 3 Sep 2020

Each rule has its own date; open a target.

Example: Arsenic (measured as As2O3) (CAS 7440-38-2)

Art. 56(4)

Must meet the conditions of Financial contributions covering separate collection, transport and treatment of waste batteries, compositional survey of mixed municipal waste, information under Art. 74 and data reporting under Art. 75

• Your role: Manufacturer or Importer or Distributor
• Contains a battery

Depends on: economic operator role, contains battery

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 6(1)

Must meet the conditions of Batteries do not contain substances restricted by Annex I unless the conditions of the restriction are met

• Your role: Manufacturer or Importer or Distributor
• Contains a battery

Depends on: economic operator role, contains battery

In force since 18 Feb 2024

Applies to products placed on the market on or after 18 Feb 2024

Applies from 2024-02-18 (Art. 96(2)); the provision states no other date.

Extended producer responsibility (Arts. 56 to 76)

Must meet the conditions of Extended producer responsibility: Articles 8 and 8a of Directive 2008/98/EC and Chapter VIII (collection, treatment, financing, reporting)

• Your role: Manufacturer or Importer or Distributor
• Contains a battery

Depends on: economic operator role, contains battery

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 59(1)

Must meet the conditions of Separate collection of all waste portable batteries in the Member State where they are first made available, with a take-back and collection system

• Your role: Manufacturer or Importer or Distributor
• Contains a battery
• Battery category: Portable battery

Depends on: economic operator role, contains battery, battery category

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 59(2)

Must meet the conditions of Take-back and collection system of collection points set up with distributors, treatment facilities, public authorities or voluntary points, covering the whole territory of the Member State

• Your role: Manufacturer or Importer or Distributor
• Contains a battery
• Battery category: Portable battery

Depends on: economic operator role, contains battery, battery category

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 59(3)(a)

Must meet the conditions of Attain and maintain durably the collection target for waste portable batteries: at least 45 % (2025-08-18), calculated under Annex XI

• Your role: Manufacturer or Importer or Distributor
• Contains a battery
• Battery category: Portable battery

Depends on: economic operator role, contains battery, battery category

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Target date 2023-12-31 as stated; Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 59(3)(b)

Must meet the conditions of Attain and maintain durably the collection target for waste portable batteries: at least 63 % (2027-12-31), calculated under Annex XI

• Your role: Manufacturer or Importer or Distributor
• Contains a battery
• Battery category: Portable battery

Depends on: economic operator role, contains battery, battery category

Takes effect 31 Dec 2027

Applies to products placed on the market on or after 31 Dec 2027

Target date 2027-12-31 as stated; Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 59(3)(c)

Must meet the conditions of Attain and maintain durably the collection target for waste portable batteries: at least 73 % (2030-12-31), calculated under Annex XI

• Your role: Manufacturer or Importer or Distributor
• Contains a battery
• Battery category: Portable battery

Depends on: economic operator role, contains battery, battery category

Takes effect 31 Dec 2030

Applies to products placed on the market on or after 31 Dec 2030

Target date 2030-12-31 as stated; Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Authorised representative for EPR (Art. 56(3))

Registration required

Appointment, by written mandate, of an authorised representative for extended producer responsibility in each Member State where batteries are sold

• Sells by distance contract to end-users in a Member State where it is not established
• Contains a battery

Depends on: distance sale to other member state, contains battery

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Art. 96(2)(c): Chapter VIII applies from 18 August 2025.

Producer registration (Art. 55(2)) of producers of batteries incorporated in appliances; a registration duty, not an information duty

Registration required

Register of producers of each Member State where the product with an incorporated battery is first made available (Art. 55(2): producers register before making batteries, including those incorporated in appliances, available)

• Your role: Manufacturer or Importer or Distributor
• Contains a battery

Depends on: economic operator role, contains battery

In force since 18 Aug 2025

Applies to products placed on the market on or after 18 Aug 2025

Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Art. 11 design for removal

Must meet the conditions of Appliances are designed so that waste batteries and accumulators can be readily removed (by the end-user, or where not, by independent qualified professionals)

• Contains a battery
• Your role: Manufacturer

Depends on: contains battery, economic operator role

In force since 26 Sep 2008

Applies to products placed on the market on or after 26 Sep 2008

Member States apply the Directive by 26 September 2008 (Art. 26); Reg. 2023/1542 Art. 95(a): Art. 11 continues to apply until 18 February 2027; the last day it applies is 17 February 2027.

Art. 11 removal instructions

Disclosure to consumer

Instructions on how the incorporated batteries and accumulators can be safely removed by the end-user or by independent qualified professionals; where appropriate, the types of battery incorporated

• Contains a battery
• Your role: Manufacturer

Depends on: contains battery, economic operator role

In force since 26 Sep 2008

Applies to products placed on the market on or after 26 Sep 2008

Member States apply the Directive by 26 September 2008 (Art. 26); Reg. 2023/1542 Art. 95(a): Art. 11 continues to apply until 18 February 2027; the last day it applies is 17 February 2027.

Distributor verification of manufacturer and importer marking before making a product available

Test required

Before making a product available, verify that the manufacturer and importer complied with Art. 9(5), (6) and (7) and Art. 11(3) and (4)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Distributor

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products distributed on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Distributor verification of manufacturer and importer marking before making a product available

Must meet the conditions of Regulation (EU) 2023/988 Art. 5 general safety requirement (storage and transport conditions)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Distributor

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products distributed on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Responsible person name and contact details on the product, packaging, parcel or document

Label required

name, registered trade name or registered trade mark and contact details, including postal and electronic address, of the Union economic operator responsible; on the product or on its packaging, the parcel or an accompanying document

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the economic operator responsible in the Union (Art. 16(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the economic operator responsible in the Union does not owe it.

An economic operator established in the EU, responsible for the product

Must meet the conditions of Regulation (EU) 2023/988 Art. 16(1): an economic operator established in the Union responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Regulation applies from 13 December 2024 (Art. 52). Obligations are on the economic operator named in the quoted article; the schema has no operator-role condition, so the rule is encoded category-wide. GPSR applies in so far as no Union harmonisation legislation covers the same safety aspects. Duty of the manufacturer or importer who places the product on the market (Art. 16(1)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer or importer who places the product on the market does not owe it.

Placing or making available products that are not safe (general safety requirement)

Must meet the conditions of Regulation (EU) 2023/988 Art. 5 general safety requirement

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Importer name and contact details on the product

Disclosure to consumer

verify that the complaint and accident communication channels of Article 9(11) are publicly available to consumers, and provide them if not

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the importer (Art. 11(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the importer does not owe it.

Importer verification of product safety and manufacturer compliance before placing on the market

Test required

Before placing a product on the market, ensure it complies with the general safety requirement (Art. 5) and that the manufacturer has complied with Art. 9(2), (5) and (6)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).