Regulatory Update: Thermal Label Materials for Food Applications

The European Union has introduced an important regulatory update for thermal label materials used in food applications. Regulation (EU) 2024/3190 introduces restrictions on the intentional use of certain bisphenols, including Bisphenol S (BPS), in food contact materials.

Which labels are covered?

The regulation is relevant when thermal labels are applied to food packaging. This includes applications such as meat, dairy, ready meals and bakery packaging, where the suitability of the label material must be assessed for the intended use.

Thermal labels used for logistics, warehousing or other non-food applications are not affected in the same way. The determining factor is the intended application on food packaging.

20 July 2026 transition date

Thermal label materials containing BPS may be placed on the market for food packaging applications until 20 July 2026. After this date, compliant materials must be used for food applications.

What changes for label selection?

• Check current declarations of compliance and technical documentation for materials used on food packaging.
• Identify food-compliant alternatives in advance and prepare a transition plan.
• Clearly distinguish materials intended for food applications from those reserved for non-food use.
• When changing materials, verify print performance, readability, adhesion and process compatibility.

Clarifying product names

The update also calls for product names to communicate the intended application more clearly. Some thermal-layer terms may be simplified to avoid suggesting that a statement applies to the entire laminate structure. Products reserved for non-food use may use names that clearly indicate logistics applications.

A naming clarification alone does not mean that the raw material formulation, EAN codes or technical performance have changed. Its purpose is to describe the intended use more transparently.

Practical checklist

1. Separate current thermal label applications into food and non-food use.
2. Update declarations of compliance and technical data for food packaging applications.
3. Confirm production and supply lead times for alternative materials before 20 July 2026.
4. Align new product names with stock records and purchasing descriptions.
5. Repeat print, adhesion and barcode readability checks during the first production runs after the transition.

This article is provided for general technical information. Current compliance documentation and applicable legislation should be verified for each specific product and application.