Thailand is proposing a mandatory standard for food contact materials and articles made of thermoset plastics derived from formaldehyde. Comments for the draft standard are accepted until April 14, 2019.

SAFEGUARDS | Hardgoods NO. 039/19

Colorful plastic containers

In February 2019, the World Trade Organization (WTO) circulated a notification announcing a draft standard from Thailand for food contact materials and articles (FCMs) manufactured from thermoset plastics with the polymerization of formaldehyde. This draft standard from the Thai Industrial Standards Institute (TISI), designated as TIS 2921-25XX(20XX) and attached to WTO document number 19-0845, is a mandatory standard for FCMs made from the following resins:

  • Melamine-formaldehyde (MF)
  • Melamine-urea-formaldehyde (MUF)
  • Urea-formaldehyde (UF)

The draft standard contains a number of important elements. These include, inter alia, the following:

  1. Scope and definitions
  2. Physical requirements
  3. Requirements for overall migration (see Table 1)
  4. Requirements for the specific migration of formaldehyde, melamine and nine heavy metals (see Tables 1 and 2) – these nine metals and their limits are identical to those under Regulation (EU) 2017/752, amending Regulation (EU) 10/2011 on ‘Food Contact Plastics’, in the European Union (EU) (Safeguard 75/17)
  5. Providing procedures and applicable analytical techniques for the test parameters in points (ii), (iii) and (iv) above
  6. Requirements for marking and labeling, including the use of the food contact safe symbol (a plate with a fork and spoon symbol, Appendix B) for compliant products
  7. Sampling criteria (Appendix A)

According to the WTO document, the final date for comments is April 14, 2019 (60 days after notification). The notification has not specified a proposed date of adoption or entry into force.

Highlights of the requirements for points (iii) and (iv) above are summarized in Tables 1 and 2 below.

Item Test Simulant Method Requirement
1 Overall migration 3% Acetic acid EN 1186 Parts 3 and 9 ≤ 10 mg/dm²
2 Specific migration of heavy metals 3% Acetic acid Article 8.4 See Table 2
3 Specific migration of formaldehyde 3% Acetic acid Article 8.5 ≤ 15 mg/kg
4 Specific migration of melamine 3% Acetic acid Article 8.6 ≤ 2.5 mg/kg

Table 1. Requirements for overall migration and the specific migration of heavy metals, formaldehyde and melamine

Item Heavy Metal Requirement for specific migration
1 Aluminum ≤ 1 mg/kg
2 Barium ≤ 1 mg/kg
3 Cobalt ≤ 0.05 mg/kg
4 Copper ≤ 5 mg/kg
5 Iron ≤ 48 mg/kg
6 Lithium ≤ 0.6 mg/kg
7 Manganese ≤ 0.6 mg/kg
8 Nickel ≤ 0.02 mg/kg
9 Zinc ≤ 5 mg/kg

Table 2. Specific migration of 9 heavy metals

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:

Rutchuporn Moungsom
Hardlines/Toys Laboratory Manager
t: +66 294 7485

Hingwo Tsang
Global Information and Innovation Manager
t: +852 2774 7420

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