Thailand Proposes Update to Law on Food Containers

SafeGuardSHardgoodsMarch 03, 2026

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

We help manufacturers and suppliers of food contact materials (FCM) achieve compliance with markets worldwide while supporting sustainability and market growth through product certification. Our experts offer extensive experience in testing materials and articles for multiple markets, ensuring they meet regulatory and environmental standards.

We provide comprehensive FCM testing, including migration tests, along with expert guidance on evolving regulations, compliance issues and documentation review. Our expertise ensures your products meet the appropriate territorial regulations for food contact materials and helps pave the way for compliance. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.

^{© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.}