Bangladesh Consults Over Draft Law on Food Contact Materials

SafeGuardSHardgoodsAugust 27, 2025

SG 124/25

Bangladesh notifies the World Trade Organization (WTO) of its draft law on food contact materials (FCMs) and articles.

On August 13, 2025, the WTO announced a proposal from the Bangladesh Food Safety Authority (BFSA) to revise the requirements for FCMs and articles under section 87 to the Food Safety Act, 2013 (Act No 43 of 2013).

Key highlights of the draft Food Safety (Food Contact Materials) Regulation, 2024 (draft Regulation), attached to WTO document 25-5099, are summarized in Table 1.

Section to draft Regulation	Highlight
2 ‘Definitions’	Establishes several terms and their definitions, including but not limited to 1) inspector, 2) label, 3) food grade, 4) overall migration limit (OML), 5) primary food packaging, 6) specific migration limit (SML) and 7) standard (a Bangladesh Standard or, if not available, a standard made by the Codex Alimentarius Commission (CAC), the United States Food and Drug Administration (FDA) or the European Commission (EC))
3 ‘Applicability’	Details the scope of FCMs Exempts antique artifacts and public water supply equipment
5 ‘General requirements’	Mandates business operators to register as specified by BFSA Details general safety requirements, including those for plastic containers, glass bottles and tin containers Prohibits printed surfaces from being in direct contact with food Bans newspapers and similar materials from being used for serving, storing and wrapping food
6 ‘Basic criteria for FCMs’	Specifies basic criteria for the following FCMs: Paper and board Glass containers Metals and alloys, including ≤ 60 mg/kg or ≤ 10 mg/dm² OM for materials with a polymer or lacquer coating Plastics, including: Either ≤ 60 mg/kg or ≤ 10 mg/dm² OM, with no visible color migration using the simulants and test conditions in Annex I, or Within SMLs for 11 elements in Schedule I (see Table 2 below) Requires food business operators to select packaging materials only from those listed in Schedule II
8-15	Details requirements for quality assurance, traceability, labeling of FCMs and packaged food, inspection, notices and manufacturing

Table 1

Entry	Substance	Maximum migration limit (mg/kg)
1	Barium	1.0
2	Cobalt	0.05
3	Copper	5.0
4	Iron	48.0
5	Lithium	0.6
6	Manganese	0.6
7	Zinc	25.0
8	Antimony	0.04
9	Phthalic acid, bis(2-ethylhexyl) ester (DEHP)	1.5
10	Bisphenol A (BPA)	0.05
11	Lead	2

Table 2. SML for substances in food contact plastics (per Schedule I)

According to the WTO and the draft Regulation, the law is intended to apply from mid-2026, with the current Food Safety (Food Contact Material) Regulation, 2019, being repealed.

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