SG 034/26
Thailand initiates consultation over proposed revision to law on food containers.
On February 11, 2026, Thailand’s Food and Drug Administration (FDA) launched a consultation over its proposed amendment to the nation’s law on food containers under the Ministry of Public Health (MOPH) Announcement No. 92 (B.E. 2528 (1985)).
Details of the proposed amendment include:
- Establishing a new structure for the law with strengthened requirements for chemicals
- Adding requirements for packaging materials made from materials other than plastic
- Requiring compliance with relevant Thai Industrial Standards (TIS), especially those governing the use of chemicals
- Issuing separate announcements for each type of material to facilitate future revisions:
- Strengthening requirements for ceramics
- Removing the scope of metal coated articles
- Inclusion of metal, glass and paper containers
Key changes in the proposed amendment are summarized in Table 1.
| Container type | Highlight of proposed change |
|---|
| Ceramics | - Reduces the number of product categories from five to three by removing ‘infant-food containers’ and ‘cooking pots’
- Updates requirements for quality or general standards, including the use of food contact grade colorants with no observable migration
- Prohibits the transfer of substances into food in quantities that could endanger human health, except that lead and cadmium must conform to TIS 601-2546 (2003) for earthenware, TIS 602-2546 (2003) for stoneware and TIS 564-2546 (2003) for porcelain, or standards as notified in future announcements
- Sets the date of entry into force (EIF) as the day following its publication in the Royal Gazette
- Mandates industry to comply with the requirements two years after the date of EIF of the new law
|
| Metals | - Introduces the term ‘metal containers’, with a definition. These are made from tin-plated steel sheets, tin-free chromium-plated steel sheets, aluminum sheets or aluminum foil
- Updates requirements for quality or general standards, including the use of food contact grade colorants with no observable migration
- Mandates the use of TIS 90-2563 (2020) for metal cans coated with a lacquer, or TIS 735-2550 (2007) for lacquer coatings that are in direct contact with food on the inside of metal containers
- Prohibits BFDGE and NOGE
- ≤ 9 mg/kg or ≤ 9 mg/6 dm² sum of migration of BADGE, BADGE.H2O (CAS 76002-91-0) and BADGE.2H2O (CAS 5581-32-8)
- ≤ 1 mg/kg or ≤ 1 mg/6 dm² sum of migration of BADGE.HCl (CAS 13836-48-1), BADGE.2HCl (CAS 4809-35-2) and BADGE.H2O.HCl (CAS 227947-06-0)
- Regulates the migration of 24 substances from artificial tap water (ATP) or 0.5% citric acid, of which 22 have specific migration limits (SMLs)
- Prohibits bisphenol A (BPA) and its salts (limit of detection (LOD) = 1 µg/kg)
- Restricts per- and polyfluoroalkyl substances (PFAS):
- ≤ 25 ppb any PFAS tested with target analysis (excluding polymeric PFAS)
- ≤ 250 ppb sum of individual PFAS, where applicable with prior degradation of precursors (excluding polymeric PFAS)
- ≤ 50 ppm PFAS, including polymeric PFAS
- Regulates PFAS in metal containers with a plastic coating according to announcements by the MOPH
- Sets the date of EIF as the day following its publication in the Royal Gazette
- Provides a transitional period of three or five years to allow industry to comply with certain provisions, such as those for BPA, BADGE, BFDGE, NOGE and PFAS
|
| Glass | - Introduces the term ‘glassware’ and its two categories (flatware and holloware), with definitions
- Updates requirements for quality or general standards
- Mandates lead, cadmium and alkalinity (calculated as sodium oxide (Na2O)) to conform to TIS for food-glassware, or be certified against TIS 603-2546 (2003) for food-glassware, or standards as notified in future announcements
- Sets the date of EIF as the day following its publication in the Royal Gazette
- Mandates industry to comply with the requirements two years after the date of EIF of the new law
|
| Paper | - Introduces the term ‘paper containers’, with definition
- Plans to define coating materials to establish their safety requirements
- Improves the requirements for quality or general standards, including those for paper containers with a coating
- Mandates the use of two national standards for chemicals: TIS 2948-2562 (2019) for food contact paper and TIS 3438-2565 (2022) for those for cooking with heat (SafeGuardS 3/26), or those notified in future announcements, except BPA and its salts must not be detected (LOD = 1 µg/kg)
- Prohibits BFDGE and NOGE
- Restricts BADGE and its derivatives, with specifications as for ‘metals’ above
- Restricts PFAS, with specifications as for ‘metals’ above
- Sets the date of EIF as the day following its publication in the Royal Gazette
- Provides a transitional period of three or five years to allow industry to comply with certain provisions, such as those for BPA, BADGE, BFDGE, NOGE and PFAS
|
Table 1
Comments will be accepted until March 31, 2026.
Abbreviations
| Abbreviation | Name |
|---|
| BADGE (CAS 1675-54-3) | 2,2-bis(4-hydroxyphenyl)propane bis(2,3-epoxypropyl) ether |
| BFDGE (CAS 39817-09-9) | Bis(hydroxyphenyl)methane bis(2,3-epoxypropyl)ethers |
| NOGE | Novolac glycidyl ethers |
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