SGS, the world’s leading testing, inspection and certification company, are advising manufacturers and suppliers of food contact plastic materials and articles that new legislation came into force in Thailand on June 18, 2022.
The new rules were published in Government Gazette, Special Edition, Volume 139, Chapter 139 on June 17, 2022. Important provisions include:
- New general safety requirements
- New definitions for containers made from plastic and containers made from recycled plastics. The latter has special rules relating to recycled material processing
- Plastic containers for milk and dairy products must be made from:
- Polyethylene (PE)
- Ethylene 1-alkene copolymerized resin
- Polypropylene (PP)
- Polystyrene (PS)
- Polyethylene terephthalate (PETP)
- Plastic containers cannot be used as food contact plastic articles if they have been used for fertilizers or other hazardous substances
Under List Number 1, 12 specific food contact plastic containers and plastic containers for milk or milk products must conform to:
- No greater than 10 mg/dm² for overall migration (Table 1)
- Specific migration of 19 heavy metals (Table 2):
- Aluminum (Al)
- Antimony (Sb)
- Arsenic (As)
- Barium (Ba)
- Cadmium (Cd)
- Cobalt (Co)
- Copper (Cu)
- Chromium (Cr)
- Lead (Pb)
- Iron (Fe)
- Lithium (Li)
- Manganese (Mn)
- Mercury (Hg)
- Nickel (Ni)
- Zinc (Zn)
- Europium (Eu)
- Gadolinium (Gd)
- Lanthanum (La)
- Terbium (Tb)
- Not detected (ND), Limit of Detection (LOD) = 0.002 mg/kg, for the specific migration of each of the 22 primary aromatic amines (PAA, Table 3.1)
- Specific migration limits (SML) for the following PAA in Table 3.2:
- ND (LOD = 0.002 mg/kg) for 1, 3-phenylenediamine (1,3-diaminobenzene, CAS 108-45-2, item 1)
- 0.05 mg/kg for 4,4’-methylene bis(3-chloro-2,6-diethylaniline (CAS 106246-33-7, item 2)
- 5 mg/kg 4,4’-diaminodiphenyl sulphone (CAS 80-08-0, item 3)
- 0.05 mg/kg for 2-aminobenzamide (CAS 88-68-6, item 4)
- No greater than 0.01 mg/kg for sum of the specific migration of PAA, other than those in Table 3.1 and items 1 to 4 in Table 3.2 (LOD = 0.002 mg/kg)
The rules require that specific plastics conform to the specific migration limits for certain substances/entries of substances (List Number 1, Table 4):
- Polyvinyl chloride (PVC, 1 substance)
- Polyvinylidene chloride (PVDC, 1)
- Polycarbonate (PC, 3)
- Polyamide/nylon (PA/Nylon, 1)
- Polymethyl methacrylate (PMMA, 1)
- Melamine-formaldehyde (3)
- Polyethylene terephthalate (PETP, 28)
The new rules also define the safety assessment documentation requirements for plastic containers that are not within the scope of the list of 12 types of plastic, and plastic containers for milk or dairy products, and detail the specifications for 12 types of food contact plastics as well as the types of plastic for containing milk or milk products (List Number 2, Tables 1 and 2).
SGS’s original SafeGuardS contains an overview of the new rules including greater detail on the requirements relating to the 19 heavy metals with specific migration limits. See SafeGuardS 082.22 for more information.
The new law repealed Notification of the Ministry of Public Health (No. 295) B.E. 2548 (2005). It contains two addition provisions with a delayed entry into force date of June 17, 2025:
- Food contact materials and articles made from virgin plastics that were in use prior to this notification may continue to be used until this date
- Food contact plastics complying with List Number 2 at the end of the notification may continue to be used until this date
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 Issues 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) 2 481 5259
Email: crs.media@sgs.com
Website: www.sgs.com/hardlines
LinkedIn: sgs-consumer-goods-&-retail
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