Thailand Circulates Proposal to Amend Food Contact Plastic Legislation

SGS, the world’s leading testing, inspection and certification company, is advising stakeholders that Thailand has announced proposals to replace its legislation relating to food contact plastics.

The World Trade Organization (WTO) circulated a draft notification from Thailand’s Food and Drug Administration in January 2022. Its provisions include:

  • General safety requirements
  • Rules for recycling processes to manufacture food contact recycled plastics
  • Plastic containers for milk and dairy products must be made from polyethylene (PE), ethylene 1-alkene copolymerized resin, polypropylene (PP), polystyrene (PS) or polyethylene terephthalate (PETP)
  • Specifies a list of 12 specific plastic containers, and plastic containers for milk and milk products, under List Number 1 to the Annex, to conform to the following:
    1. Specific migration limits (SML) for 20 heavy metals
    2. No more than 10 mg/kg for overall migration
    3. No more than 0.002 mg/kg for the specific migration of each of the 22 primary aromatic amines (PAAs)
    4. No more than 0.002 mg/kg for the specific migration of 1, 3-phenylenediamine
  • List of PAAs falling under Table 1 to Annex I of Regulation (EU) 10/2011 ‘Union list of authorized monomers, other starting substances, macromolecules obtained from microbial additives and polymer production aids,’ as amended (Item 3 to Table 3 of List Number 1) – no more than 0.002 mg/kg for the specific migration of each PAA and not greater than 0.01 mg/kg for the sum of PAAs, other than PAAs in the aforementioned Items 1-3 to Table 3 of List Number 1
  • Specific plastics required to conform to the specific migration of certain substances/entries of substances:
    1. Polyvinyl chloride (PVC)
    2. Polyvinylidene chloride (PVDC)
    3. Polycarbonate (PC)
    4. Nylon/polyamide (Nylon/PA)
    5. Polymethyl methacrylate (PMMA)
    6. Melamine
    7. Polyethylene terephthalate (PETP)
  • Safety assessment documentation requirements defined for plastic containers that are not within the scope of the list of 12 types of plastic, and plastic containers for milk and dairy products
  • Prohibits plastic containers, such as food contact plastic articles, if these have been used to package fertilizers or other hazardous substances

The proposal also states that food contact materials and articles made from virgin plastic, which were in use prior to this notification, may continue to be used for no more than three years from the date of entry into force.

Stakeholders are advised to review SGS’s original SafeGuard 026/22 to learn more about Thailand’s proposals and see a complete list of heavy metals and SMLs.

If accepted, the proposal will repeal Notification of the Ministry of Public Health (No. 295) B.E. 2548 (2005). It will then enter into force on the day after its publication in the Government Gazette.

SGS Food Contact Material Services

SGS’s technical experts have extensive experience of testing materials and articles in contact with food. They can ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. SGS offers the full range of testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. In the end, it’s only trusted because it’s tested. Learn more about SGS’s Food Contact Material Services.

SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full Thailand Proposes New Legislation for Food Contact Plastics SafeGuardS.

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For further information contact:

Dr. HingWo Tsang

Global Information and Innovation Manager

Tel: (+852) 2774 7420

Rutchuporn Moungsom

Hardlines/Toys Laboratory Manager

Tel: +66 2 294 7485



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