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Turkey Strengthens Regulation on Food Contact Plastics

SafeGuardSFood Contact Material, Consumer Goods and Retail Hardgoods Food Contact MaterialJanuary 09, 2020

Turkey is aligning its Regulation on food contact plastics with those from the European Union. The new laws will become effective on December 31, 2020.

In 2018, Turkey published its Food Contact Materials and Articles Regulation under Number 30382 of April 5, 2018. This framework legislation established 17 categories of food contact materials and articles, and contains, inter alia, provisions for paper and boards, metals and alloys, as well as colorants/dyes for plastics.

In December 2019, Turkey published two Notifications to (essentially) align its food contact plastics with those from Regulation (EU) 10/2011 in the European Union. The two Notifications are:

  • Notification No. 2019/43 under Number 30989 (Repeat) of December 25, 2019 ‘Turkish Food Codex Communication on Food Simulants used in Migration Tests for Plastic Materials and Articles Intended to Come into Contact with Food’ – repeals Notification No. 2013/35 in Number 28710 of July 17, 2013
  • Notification No. 2019/44 under Number 30989 (Repeat) of December 25, 2019 ‘Turkish Food Codex Communication on Plastic Materials and Articles Intended to Come into Contact with Food’ – repeals Notification 2013/34 in Number 28710 of July 17, 2013

Under Regulation (EU) 2017/752 amending Regulation (EU) 10/2011 on food contact plastics, FCM substance No 1062 - mixture composed of 97% tetraethyl orthosilicate (TEOS) with CAS No 78-10-4 and 3% hexamethyldisilazane (HMDS) with CAS No 999-97-3, is on the Union list of authorized substances and allowed to be used in the manufacture of recycled polyethylene terephthalate (recycled PET) with certain restrictions. It is interesting to note that this substance is not on the list of permitted substances under Table 1 to Annex 1 of Turkish Notification No. 2019/44. 

Both of the Notifications entered into force on December 25, 2019 – the date of their publication in the T.C. Resmi Gazete. Their provisions will become effective on December 31, 2020.

Highlights of certain provisions falling under Notification Nos. 2019/43 and 2019/44 are summarized in Table 1.  Unless otherwise stated, these certain provisions are from Notification No. 2019/44 under Number 30989 (Repeat) of December 25, 2019.

(Article 2)
  • Materials and articles and parts thereof made entirely of plastics
  • Plastic multi-layer materials and articles that are held together by adhesives or other means
  • Materials and articles in the two points above that are printed and/or covered by a coating
  • 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
(Article 2)
  • Ion-exchange resins, rubber and silicones
  • Rules on printing inks, adhesives and coatings
3Overall Migration Limit (OML) Requirements
(Article 8)
≤ 10 mg/dm² otherwise ≤ 60 mg/kg for FCMs intended for food for infants and young children
4Declaration of Compliance (DoC) and documentation
(Article 11)
  • The documentation contains, in part, the test conditions and results, calculations (including modeling), other analysis and evidence on the safety or reasoning demonstrating compliance
  • The rules for the above-mentioned points for documentation can be found in Articles 12 to 14 
  • Information for the DoC is in Annex 3
5List of authorized substances
(Annex 1, Table 1) 
Contains more than 1,000 entries
6Specific Migration Limit (SML) Requirements (Annex 1, Table 1)

Representative examples:

  • ≤ 30 mg/kg for benzylbutyl phthalate (BBP)*
  • ≤ 0.3 mg/kg for dibutyl phthalate (DBP)*
  • ≤ 1.5 mg/kg for bis(2-ethylhexyl) phthalate (DEHP)*
  • ≤ 9 mg/kg for the sum of diisodecyl phthalate and diisonyl phthalate (DIDP and DINP)*
  • ≤ 0.01 mg/kg (not detected) for diallyl phthalate (DAP)

* additional requirements for these phthalates when used as a technical support agent 

7SML Requirements
(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)


Food simulants 
(Annex 1 to Notification No. 2019/43) under Number 30909 (Repeat) of December 25, 2019
  • List of food simulants and rules for assigning these to migration tests
  • Specific assignment of food simulants to food categories
The above essentially aligns with Annex III to Regulation (EU) 10/2011 on food contact plastics in the EU (with amendments to Regulation (EU) 2019/1338 (see consolidated version to August 29, 2019 for further details)
Effective Date: December 31, 2020

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. 

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