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Turkey is proposing a specific piece of legislation for food contact plastics. If published in the official journal, the provisions will become effective on January 1, 2021.

SAFEGUARDS | Hardlines NO. 162/18

SafeGuardS orig colorful plastic containers

In April 2018, Turkey published Regulation number 30382 on food contact materials and articles (Safeguard 62/18 [1]). This framework legislation established 17 categories of food contact materials and articles and contains, inter alia, provisions for food contact paper and board, metals and alloys, as well as colorants/dyes for plastics.

In November 2018, the World Trade Organization (WTO) circulated a notification from Turkey announcing its proposal on a specific piece of legislation on food contact plastics. The draft legislation [2] and its annexes [3], attached to WTO document number 18-7183 [4] and notified under G/SPS/N/TUR/105, would create a new set of requirements for food contact plastics. The proposal contains, among other things, the following provisions:

  • Scope of food contact plastics
  • List of materials that are exempt from the scope of food contact plastics
  • Union list of authorized substances (Annex 1, Table 1)
  • Specific migration limits for nine heavy metals (Annex 2, see number 6 in Table 1 below)
  • Conformity analysis (Annex 4)
  • Fat Reduction Factor (FRF) correction for specific migration in foods containing more than 20% fat

According to the WTO document, the proposed date of adoption and publication of this proposal is February 1, 2019.

The requirements in the proposal are consistent with many of the provisions for food contact plastics under Regulation (EU) 10/2011 in the European Union (EU). If published in the T.C. Resmi Gazete, it will repeal Regulation number 28710 of July 17, 2013 (Communiqué No. 2013/34 [5]) on food contact plastics and the provisions will become effective on January 1, 2021.

Highlights of the proposal are summarized in Table 1.

Number Item Highlight
1 Scope
  • Materials and articles made entirely of plastics
  • Plastic multi-layer materials and articles that are held together by adhesives or by other means
  • Plastic layers or plastic coatings, forming gaskets in caps and closures, that together with those caps and closures compose a set of two or more layers of different types of material
  • Plastic layers in multi-material multi-layer materials and articles
2 Exemption Ion exchange resins, rubber and silicones
3 Union list of authorized substances Contains more than 1,000 entries
4 Overall migration limit (OML) ≤ 10 mg/dm² otherwise ≤ 60 mg/kg for food contact plastics for infants and young children
5 Specific migration limits (SML, Annex 1, Table 1) Representative examples:  
≤ 0.3 mg/kg for dibutyl phthalate (DBP)
≤ 30 mg/kg for benzylbutyl phthalate (BBP)
≤ 1.5 mg/kg for bis(2-ethylhexyl) phthalate (DEHP)
Not detected for dially phthalate (DAP)
6 Specific migration limits (SML, Annex 2) Heavy Metals:
≤ 1 mg/kg (aluminum (Al))
≤ 1 mg/kg (barium (Ba))
≤ 0.05 mg/kg (cobalt (Co))
≤ 5 mg/kg (copper (Cu))
≤ 48 mg/kg (iron (Fe))
≤ 0.6 mg/kg (lithium (Li))
≤ 0.6 mg/kg (manganese (Mn))
≤ 0.02 mg/kg (nickel (Ni))
≤ 5 mg/kg (zinc (Zn))
7 Declaration of compliance (DoC) DoC to be drawn up in accordance with Annex 3
8 Supporting documents Demonstration that materials and articles, products from intermediate stages of their manufacturing as well as substances intended for the manufacturing of those materials and articles made available to business operators and authorities on request

Table 1

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 Information and Innovation Manager
t: +852 2774 7420

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