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Global Food Contact Regulatory Updates – First half of year 2020


Global Food Contact Regulation Updates

The safety of food package is as important as the food. Government agencies around the world regulate food contact materials and food package to ensure, when used in contact with food, food contact materials and food package do not cause food unsafe and endanger human health, do not change the composition of food, and do not change the organoleptic characteristics of food. Understanding these regulations and keeping up with the new regulations are essential for maintaining market access for food contact products. In this section, we will provide global food contact regulation developments, news and updates relevant food packaging chemical safety and regulatory compliance.



Brazil has adopted a positive list of additives that can be used in the manufacture of plastic materials and in polymeric coatings intended to come into contact with food. It was adopted on 3 December and notified to the World Trade Organization one week later.


Italy announces that it will tax plastics at the rate of 0.5 Euro per kilogram, excluding products that contain recycled and biodegradable plastic . The tax is intended to go into effect in January 2020.


Japan food contact plastics Positive List came into force on June1, 2020. There is a 5-year grace period, that means, industry has until May 30, 2025 to fully in compliance with the Positive List.

In addition, the Ministry of Health, Labour and Welfare (MHLW) of Japan issued Notification stated that three amended regulations below will come in force from June 1, 2020:

  1. Revision of Food Sanitation Act (Law No. 46 of 2018 )

  2. Article 18, Part 1 of the Food Sanitation Act (Law No. 233 of 1947) (MHLW Notification No. 195)

  3. Amendment on Specifications and Standards for Food and Food Additives (MHLW Notification No. 370)

South Korea

South Korea recently updated it’s Specification and Standards for Food Utensils, Containers and Packages. In addition to adding some new testing methods updates and document formatting changes, the revision added additional requirements for recycled plastics for food contact applications. Prior to this update, South Korea allows the use of chemically recycled PET and PEN for direct food contact uses. In the new revision, it adds two new requirements for recycled plastics: 1) Recycled plastics from industry manufacturing scraps of virgin food contact plastics materials can be used for food contact applications; 2) Recycled plastics are permitted if they are used behind function barriers in food contact applications.


Thailand Food and Drug Administration (FDA) is considering updating its regulations on plastic food contact materials to allow for the use of recycled plastics in food contact applications. The Thai FDA published questionnaire to industries focusing on food contact materials composed of recycled polyethylene terephthalate (PET) and high-density polyethylene (HDPE). The information generated from the completed questionnaires will be used to determine safety standards for both types of materials.


Turkey determines the specifications for plastic materials and articles that are in contact with food and compliance testing rules in order to adapt to the EU Regulation No.10/2011 on Plastic Materials Intended to Come into Contact with Food.


A couple of US states restrict use of BPA based materials for infants and children -

Pennsylvania: An Act providing for bisphenol A-free container products for infants. No person or entity may manufacture, sell or distribute any container intended for use by infants that contains bisphenol A (BPA) at a level above 0.1 parts per billion (ppb).

Virginia: Prohibits the manufacture, sale, or distribution in the Commonwealth of any container intended for the storage of liquid food or beverages that contains BPA; the bill imposes certain requirements on any substitute chemical used by a manufacturer in place of BPA.


U.S. Senator Tom Udall (D-N.M.) and U.S. Representative Alan Lowenthal (D-Calif) are circulating a discussion draft of legislation to tackle plastic waste. The draft legislation outlines are the following: 1. Require plastic producers to take responsibility for collecting and recycling materials; 2. Require nationwide container deposits; 3. Ban certain pollutant products; 4. Carryout bag fee; 5. New minimum recycled content requirement; 6. Protect existing state action; 7. Moratorium on new plastic facilities



The EU Directorate General for Health and Food Safety, DG Sante, is conducting a survey of manufacturers/users of Food Contact Material that contain phthalates. This includes the phthalates approved for use in Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food. The EU is requesting information about plastics, coatings, silicones, rubbers, adhesives and printing inks that contain phthalates, and combinations of the previous i.e. multi-material multi-layer FCMs. The 5 phthalates allowed by 10/2011 are DBP, BBP, DEHP, DINP, DIDP

The European Commission committed to revise its decades-old legislation on chemicals in food contact materials in 2022, as part of a new strategy it has announced on sustainable food systems for the next decade. In addition, the Commission will work on a legislative initiative to substitute single-use food packaging and cutlery by reusable products, according to the strategy.


This article was written by Dr. Huqiu Zhang, Senior Scientist at Sevee & Maher Engineers, Inc. and contributor. To learn more about Dr. Zhang visit her Contributor Page.


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