18 February 2026 is a significant date for those operating in the French food packaging market. The DGCCRF (the French authority responsible for consumer protection and fraud prevention) has released a significant update to its operational guidelines. While not a new law, this update is perhaps even more impactful, providing brand owners, manufacturers, and distributors with a practical and rigorous checklist based on the EU regulatory framework.
The objective is to eliminate ambiguity in chemical safety and crack down on deceptive marketing practices concerning ‘natural’ materials. Italian companies exporting to France who ignore this document expose themselves to significant legal and reputational risks.
Beyond Primary Packaging: the extension of “Contact”
One of the key points reiterated by the DGCCRF is the breadth of the definition of materials in contact with food (MOCA). Surveillance is not limited to trays or bottles. The scope includes:
- Secondary packaging and outer packaging: If direct contact is foreseeable or reasonably possible.
- Logistics and Process: Conveyor belts, storage containers, and even industrial equipment used in shipping are subject to the same chemical inertness standards.
- Utensils: Films, bags, and containers for domestic or professional use.
“Inertness” and “intended use” are the core tests
The core of the guide lies in the principle of inertia. According to the DGCCRF, every material must be tested to ensure that, under normal or foreseeable conditions, it does not alter the composition of the food or its organoleptic characteristics (smell, taste, appearance).
However, the real challenge for manufacturers lies in defining the intended use. The guide is explicit in condemning domestic and industrial “improvisation”: the use of containers that are not suitable for heat in the oven or the reuse of single-use packaging are now under the scrutiny of the authorities.
DGCCRF also references technical guidance for printing inks, coatings and varnishes applied to the non-food-contact side of packaging, acknowledging that set-off and migration can still occur: so ink selection, curing and supplier documentation should sit inside the food-safety file, not outside it.
For packaging supply chains, the signal is clear: audit your “intended use” statements, Declarations of Compliance and marketing claims now (especially for printed structures and fibre-plastic composites) because these are the areas where enforcement is most likely to focus.
