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SAFEGUARDS | Consumer Products NO. 080/17

SafeGuardS Bread with blueberry cheese pie with black coffees

Malaysia has amended migration limits for cadmium in food contact ceramics to become less stringent. The new law took effect on April 15, 2017. The authorities also announced a three month grace period before restoring enforcement actions for consignments that are already being imported.

In Malaysia, food contact ceramics are regulated by the Thirteenth Schedule (Regulation 28) to Food Regulations 1985 [1]. Under this law, food contact ceramics are required to comply with, among others, the migration of lead and cadmium, physical/performance characteristics and labeling requirements. Labeling is exempt for food contact ceramics that are small utensils such as chopsticks, espresso cups, salt & pepper shakers, saucers and soup spoons. However, the labeling requirements shall be stated on the outer packaging for these items.

On April 3, 2017, Malaysia published Food (Amendment) (No. 2) Regulations 2017 [2] in the Federal Government Gazette to amend the Food Regulations 1985 [P.U. (A) 437/1985], the so-called ‘Principal Regulations’. There are three changes in the new law:

  • Amending migration limits for cadmium to become less stringent in Table 1, in:
    1. Small hollowware
    2. Large hollowware
  • Replacing MS ISO 6486-1 (Ceramic ware, Glass Ceramic ware and Glass Dinnerware in Contact with Food – Release of Lead and Cadmium, Part 1: Test Method) with MS 1817-1 (Ceramic Tableware – Specifications) in Table 2. This amendment is essentially editorial

The new amendment became effective on April 15, 2017. 

On April 14, 2017, Malaysia published a bulletin [3] announcing enforcement actions to control the import of ceramic ware falling under Regulation 28 of the Foods Regulations 1985.

According to the announcement, enforcement started on April 15, 2017. This announcement also granted a period of three months for consignments of ceramic ware that are already in the process of being imported into Malaysia. The import controls for each consignment of food contact ceramics complying with all the stipulated requirements in Regulation 28 of the Food Regulations 1985 will come into force on July 15, 2017. This includes Certificate of Analysis (COA) for lead and cadmium. The authorities will action Examination Level Five (5) – Hold, Test & Drop (TUL) for any consignment that does not have a COA. The importation procedures and the amendments to cadmium migration limit are also reflected in a new guidance document [4] published by the Ministry of Health, Malaysia, to assist the food contact ceramics industry. 

Highlights of migration limits for lead and cadmium between the amendment and its predecessor are summarized in Table 1.

Table 1. Regulation 28 to Food Regulations 1985 (Principal Regulations) relating to Ceramics

Food (Amendment) (No.2) Regulations 2017,
amending Table 1 to the ‘Principal Regulations’
Table 1 to the ‘Principal Regulations’
Ceramic ware Unit Lead Cadmium Lead Cadmium
Flatware mg/dm² 0.8 0.07 0.8 0.07
Small hollow ware mg/L 2.0 0.5 2.0 0.20
Large hollow ware mg/L 1.0 0.25 1.0 0.20
Effective date April 15, 2017 Superseded

Table 2: Definitions

Item Ceramic type Definition
1 Flatware Article with internal depth ≤ 25 mm
2 Small hollowware Article with internal depth > 25 mm and a capacity of < 1.1L
3 Large hollowware Article with internal depth > 25 mm and a capacity of ≥ 1.1L

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. From overall migration test to expert advices on emerging regulations and compliance issues and documentation review, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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