Food Contact Material Regulations – Asia Pacific Region
The rules governing food contact materials (FCM) in the Asia-Pacific Region are jurisdiction dependent.
Although a ‘common market’ approach is gaining momentum in this region since India, South-Korea, Japan, Australia and New-Zealand approached the ASEAN Free Trade Area (AFTA), the requirements for general safety are essentially similar to other international markets such as Europe, North America and Mercosur.
General Safety Requirements
As part of the general safety requirements, the quantity of substances transferred from FCM and articles (FCA) to food must not endanger human health or bring about unacceptable changes to the composition of food such as taste and odour.
Diversity & Complexity
The requirements in the Asia Pacific Region are highly complex and diverse. Some countries/regions, such as Hong Kong and the Philippines, recognise demonstration of compliance to requirements from the US FDA, whereas some countries such as China, Japan and South Korea require conformity assessment procedures to be carried out from approved laboratories for formal acceptance.
General Laws and/or Standards for Key Countries in this Important Region
| Jurisdiction | Legislation/standard |
|---|---|
| Australia |
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| China |
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| Hong Kong | Public Health and Municipal Services Ordinance, Chapter 132 |
| India | The Food Safety and Standards Act of 2006 (FSSA, No. 34 of 2006) |
| Indonesia |
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| Japan |
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| Malaysia | Food Regulations of 1985 (P.U. (A) 437/1985), Part VI ‘Packages for food’ |
| Philippines | Republic Act No. 10611 (Food Safety Act of 2013) |
| Singapore | Food Regulations under the Sale of Food Act, 1973 (revised 2002) |
| South Korea |
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| Taiwan |
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| Thailand |
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| Vietnam |
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Specific Measures Affecting Bisphenol A (BPA)
Similar to many jurisdictions around the world, many countries in this region restrict or prohibit the use of BPA in FCM and FCA. This includes, but is not limited to China, Japan, Malaysia and South Korea. In Australia, certain major retailers have voluntarily phased-out the use of BPA in polycarbonate plastic feeding bottles.
| Jurisdiction | Citation | Scope | Requirement |
|---|---|---|---|
| Australia | Announcement by Parliament Secretary for Health Media Release, 30 June, 2010 |
Baby bottles | Voluntary phase out by certain major retailers |
| China | Ministry of Health, Bulletin No. 15 of 2011 | Polycarbonate baby feeding bottles and other infant feeding bottles | Prohibited |
| Japan | Specifications for Food Additives, etc. under the Food Sanitation Act | Food contact polycarbonate plastics | ≤2.5 μg/mL migration (including phenol and p-tert-butylphenol) |
| Malaysia | P.U. (A) 35/12 of the Food Regulations 1985 | Feeding bottles | Prohibited |
| South Korea | Korea Food Code Section 7 | Food contact polycarbonate plastics | Prohibited |
Developments in China
FCM and FCA in China are regulated by the ‘Food Safety Law of the People’s Republic of China’. On the basis of this piece of legislation, the National Health and Family Planning Commission (NHFPC) promulgated a series of new mandatory national standards for FCM and FCA between 2015 and 2016. These new standards reflect a major change from all previous standards, which have been revised, consolidated or otherwise changed.
The two most important 2016 versions of these standards are GB 4806.1 on general safety requirements and GB 9685 on the use of additives for FCM and products. These became effective in October 2017.
In addition, to ensure compliance with specifications in all related standards, economic operators placing FCM and FCA on China’s market are required to label their products properly and provide a declaration of compliance (DoC) according to section 8 of GB 4806.1-2016.
The Framework and Mandatory GB Standards
China’s GB Standards for Food Contact Materials
| Category | Scope | Standard |
|---|---|---|
| Basic Standard | General Safety Requirements | GB4806.1-2016 |
| Additive | GB9685-2016 | |
| Product Standard | Rubber teat | GB4806.2-2015 |
| Enamel | GB4806.3-2016 | |
| Ceramic | GB4806.4-2016 | |
| Glass | GB4806.5-2016 | |
| Plastic resin | GB4806.6-2016 | |
| Plastic material and article | GB4806.7-2016 | |
| Paper and paperboard | GB4806.8-2016 | |
| Metal | GB4806.9-2016 | |
| Paint and coating | GB4806.10-2016 | |
| Rubber | GB4806.11-2016 | |
| Determination Standard | General principles of pre-treatment methods for migration test | GB5009.156-2016 |
| General principles for migration test | GB31604.1-2015 | |
| Nine test method standards | GB31604.2-2016 to GB31604.10-2016 |
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| 39 test method standards | GB31604.11-2016 to GB31604.49-2016 |
Food Safety Testing
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.