Turkey More Closely Aligns Food Contact Plastics Regulations With the EU

December 2019, Turkey published two notifications that more closely align its
regulations for food contact plastics with those of the European Union’s
Regulation (EU) 10/2011.

two notifications are:

  • Notification No. 2019/43 under Number 30989 (Repeat) of December 25, 2019 ‘Turkish Food Codex Communication on Food Simulants used in Migration Tests for Plastic Materials and Articles Intended to Come into Contact with Food’ – repealing Notification No. 2013/35 in Number 28710 of July 17, 2013
  • Notification No. 2019/44 under Number 30989 (Repeat) of December 25, 2019 ‘Turkish Food Codex Communication on Plastic Materials and Articles Intended to Come into Contact with Food’ – repealing Notification
    in Number 28710 of July 17, 2013

to Notification No. 2019/44, the scope of these regulations, covered in Article
2, is:

  • Materials and articles and parts thereof made entirely of plastics
  • Plastic multi-layer materials and articles that are held together by adhesives or other means
  • Materials and articles in the two points above that are printed and/or covered by a coating
  • Plastic layers or plastic coatings, forming gaskets in caps and closures that together with those caps and closures compose a set of two or more layers of different types of material
  • Plastic layers in
    multi-material multi-layer materials and articles

No. 2019/44 does not cover:

  • Ion-exchange resins, rubber and silicones
  • Rules on printing
    inks, adhesives and coatings

should also be aware that the overall migration limit (OML) requirement,
contained in Article 8 of No. 2019/44, is ≤ 10 mg/dm², otherwise ≤ 60 mg/kg for
FCMs intended for food for infants and young children.

list of authorized substances contained within Annex 1 Table 1 of No. 2019/44
runs to over 1000 substances. It includes specific migrations limits (SMLs) for
several common substances, for example:

  • ≤ 30 mg/kg for benzylbutyl phthalate (BBP)
  • ≤ 0.3 mg/kg for dibutyl phthalate (DBP)
  • ≤ 1.5 mg/kg for bis(2-ethylhexyl) phthalate (DEHP)
  • ≤ 9 mg/kg for the sum of diisodecyl phthalate and diisonyl phthalate[TH(K1] (DIDP and DINP)
  • ≤ 0.01 mg/kg (not
    detected) for diallyl phthalate (DAP)

should be aware that there are additional requirements for BBP, DBP. DEHP, DINP
and DIDP, when used as a technical support agent.

for heavy metals include:

  • Aluminum: ≤ 1 mg/kg
  • Barium: ≤ 1 mg/kg
  • Cobalt: ≤ 0.05 mg/kg
  • Copper: ≤ 5 mg/kg
  • Iron: ≤ 48 mg/kg
  • Lithium: ≤ 0.6 mg/kg
  • Manganese: ≤ 0.6 mg/kg
  • Nickel: ≤ 0.02 mg/kg
  • Zinc: ≤ 5 mg/kg

two notifications also contain provisions relating to Declaration of Compliance
(DoC) and documentation (No. 2019/44 Article11) and food simulants (No. 2019/43
Annex 1).

is interesting to note that the Turkish regulations are not completely aligned
with the EU regulations. For example, under Regulations (EU) 2017/752, which
amends Regulations (EU) 10/2011, food contact material substance
No 1062 – a mixture composed of 97% tetraethyl orthosilicate (TEOS) and 3%
hexamethyldisilazane (HMDS) – is on the authorized list of substances and is
allowed in the manufacture of recycled polyethylene terephthalate (recycled
PET) with certain restrictions. This substance is absent from the Turkish

published its Food Contact Materials and Articles Regulation in 2018. The
latest notifications came into force on December 25, 2019 and will become
effective on December 31, 2020.

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
Learn more about SGS’s Food Contact Material Services.

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Tel:(+852) 2774 7420

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Tel: +90 212 368 40 00 (Ext 4205)

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