India has published a completely new piece of legislation to regulate food contact materials and articles. The new law will become effective on July 1, 2019.

SAFEGUARDS | Hardgoods NO. 019/19

SafeGuardS vegetable salad in craft package take away

In December 2018, the Indian Ministry of Health and Family Welfare published the ‘Food Safety and Standards (Packaging) Regulations, 2018 (1), to regulate food contact materials and articles (FCM). This new piece of legislation replaces all provisions relating to packaging requirements under the ‘Food Safety and Standards (Packaging and Labelling) Regulations, 2011’. 

The new law contains a number of important provisions. These include, inter alia, the following:

  • Specifying a list of Indian Standards (IS) for specific applications in food contact paper and board, metal and metal alloys, and plastics (Schedules I to III)

  • Specifying a list of suggestive packaging materials for certain product categories of food (Schedule IV)

  • ≤ 60 mg/kg or ≤ 10 mg/dm² for overall migration and with no visible color migration for food contact plastics

  • Requiring food contact plastics to comply with the specific migration of seven heavy metals (Table 1, see Table 1 below). These migration limits are identical to those in Regulation (EU) 10/2011 (2) as originally published

  • Prohibition of recycled plastics for the manufacture of food contact materials and articles

  • Allowing the use of appropriate International Standards where Indian Standards are not available

  • Specifying the use of IS 15495 for printing inks for use on FCM

  • Requiring all business operators to obtain the certificate of conformity issued by laboratories accredited by the National Accreditation Board for Testing and Calibration Laboratories (NABL)

 The new law will become effective on July 1, 2019.

 Highlights of the requirements for the specific migration of heavy metals in food contact plastics are summarized in Table 1.


Food Safety and Standards (Packaging) Regulations, 2018,
Table 1 ‘Requirements for Specific Migration Limits of Substances from Plastic Materials Intended to be in Contact with Articles of Food
The Gazette of India, Number 535, December 24, 2018
Item Heavy Metal Specific migration requirement Item Heavy Metal Specific migration requirement
1 Barium ≤ 1.0 mg/kg 5 Lithium ≤ 0.6 mg/kg
2 Cobalt ≤ 0.05 mg/kg 6 Manganese ≤ 0.6 mg/kg
3 Copper ≤ 5.0 mg/kg 7 Zinc ≤ 25.0 mg/kg
4 Iron ≤ 48.0 mg/kg

Next step:

Stakeholders are advised to comply with the latest requirements for food contact materials and articles for India.

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

Jai Praveen
Assistant Manager
t: +91 98 116 77219

Ashwani Verma
Manager Operation
t: +91 98 103 13721


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