Montenegro Regulates Food Contact Regenerated Cellulose Films

SG 160/24

Montenegro has published its rulebook on food contact regenerated cellulose film materials and articles. The new law became effective on October 19, 2024.

In 2016, Montenegro issued the nation’s regulation on materials and articles intended to come into contact with food (Official Gazette of Montenegro, No. 80/216 (OMG No. 80/2016)). It established different types of food contact material and articles where specific measures may be adopted or amended, requirements for general safety, traceability, good manufacturing practice (GMP), active and intelligent materials and articles, declaration of conformity (DoC), civil penalties and the use of the wine glass and fork symbol for ‘food contact safe’.

This piece of legislation adopted provisions from Regulation (EC) No.1935/2004, the framework regulation for food contact materials and articles in the European Union (EU).

On October 11, 2024, Montenegro’s Ministry of Agriculture, Forestry and Water Management (Ministarstvo poljoprivrede, šumarstva i vodoprivrede) published its rulebook for regenerated cellulose film materials and articles intended to come into contact with food (the Rulebook, OMG No. 98/2024). The new law transposes EU Directive 2007/42/EC on food contact regenerated cellulose films.

OMG No. 98/2024 contains several important provisions. It:

• Provides a definition for regenerated cellulose film and specifies that this definition belongs to one of the following types:
• Regenerated cellulose film without coating (Article 3(2)(1))
• Regenerated cellulose film with a coating derived from cellulose (Article 3(2)(2))
• Regenerated cellulose film with a plastic coating (Article 3(2)(3))


• Indicates that regenerated cellulose films under Articles 3(2)(1) and 3(2)(2) must be manufactured, with certain exceptions, using the substances or groups of substances in Appendix 1
• Permits regenerated cellulose film with a plastic coating to be manufactured, before being coated, using only the substances or group of substances specified in Appendix 1
• Only allows authorized substances falling under special conditions for food contact plastics to be used for the manufacture of plastic coatings
• Prohibits the printed surfaces of the regenerated cellulose film to come into contact with food
• Requires food contact regenerated cellulose films to be accompanied by a DoC at the marketing stages other than the retail stages – this DoC is not required if regenerated cellulose film materials and articles are clearly intended for food contact by their nature
• Requires regenerated cellulose film materials and articles to be labeled accordingly if special conditions of use are indicated

The Rulebook became effective on October 19, 2024 – the eighth day from its publication in the OGM.

SGS has the expertise to help manufacturers and suppliers of FCM achieve compliance with markets around the globe. Our technical experts have extensive experience of testing materials and articles for many markets. We offer the full range of FCM testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Our experience can ensure your products meet the appropriate territorial regulations for food contact materials and help pave the way for compliance. Contact us to know more or visit our website. In the end, it’s only trusted because it’s tested.