SG 132/23
Ukraine has initiated a 10-day consultation on its draft order on food contact plastics. If approved, the provisions will become effective on November 19, 2025.
On October 2, 2023, Ukraine’s Ministry of Health announced draft Order ‘On Approval of Special Requirements for Plastic Materials and Articles Intended to Come into Contact with food’.
The draft order intends to approve a set of ‘special requirements’ for food contact plastics by implementing Regulation (EU) 10/2011 from the European Union (consolidated version to August 2023 for reference). It:
Draft Order of the Ministry of Health of Ukraine, October 2, 2023
Appendix 2 to Special Requirements for Plastic Materials and Articles Intended to Come into Contact with Food (per draft order text)
| Item | Substance | SML (mg/kg) |
|---|---|---|
| 1 | Aluminum | 1 |
| 2 | Ammonium | --- |
| 3 | Antimony | 0.041 |
| 4 | Arsenic | Not detected (ND) (Detection limit = 0.01) |
| 5 | Barium | 1 |
| 6 | Cadmium | ND (Detection limit = 0.002) |
| 7 | Calcium | --- |
| 8 | Chromium | ND (Detection limit = 0.012 |
| 9 | Cobalt | 0.05 |
| 10 | Copper | 5 |
| 11 | Europium | 0.053 |
| 12 | Gadolinium | 0.053 |
| 13 | Iron | 48 |
| 14 | Lanthanum | 0.053 |
| 15 | Lead | ND (Detection limit = 0.01) |
| 16 | Lithium | 0.6 |
| 17 | Magnesium | --- |
| 18 | Manganese | 0.6 |
| 19 | Mercury | ND (Detection limit = 0.01) |
| 20 | Nickel | 0.02 |
| 21 | Potassium | --- |
| 22 | Sodium | --- |
| 23 | Terbium | 0.053 |
| 24 | Zinc | 5 |
1 SML may be exceeded at very high temperature
2 Less stringent limit of 3.6 mg/kg applies if pre-existing documentation demonstrates Cr (VI) is excluded
3 Lanthanides (europium, gadolinium, lanthanum, and/or terbium) can be used according to Clause 4(2) of Section III to the Special Requirements subject to SML is no more than 0.05 mg/kg for the sum of all lanthanide substances and the analytical evidence using a procedure demonstrating the lanthanide substance(s) used are present in dissociated ionic form in food or food simulant forms part of the documentation in Clause 10 of Section III to Special Requirements
Table 1
It is interesting to note that the draft order has not adopted Regulation (EU) 2023/1627 – amendment 17 to Regulation (EU) 10/2011 (SafeGuardS 102/23)
If approved, the order will apply from November 19, 2025 – the same day as the Law of Ukraine of November 3, 2022 No. 2718-IX ‘On materials and articles intended to come into contact with food’ (SafeGuardS 135/22)
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, paving the way for compliance. From overall migration tests to expert advice on emerging regulations, compliance issues and documentation review, SGS is the partner to trust. Discover more on 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.
