Thailand has informed the WTO of its intention to replace its legislation on food contact plastics. The new law would enter into force on the day after its publication in the Government Gazette.

SAFEGUARDS | HardgoodsNO. 026/22

 SG 02622 Food Container

In January 2022, the World Trade Organization (WTO) announced a draft notification from Thailand’s Food and Drug Administration on its intention to set out new rules for food contact plastics. 

The draft notification, attached to WTO document 22-0680, and notified under G/SPS/N/THA/484, contains several important provisions:

  • Sets out the general safety requirements
  • Details the rules for recycling processes to manufacture food contact recycled plastics 
  • Requires plastic containers for milk and dairy products to be made from polyethylene (PE), ethylene 1-alkene copolymerized resin, polypropylene (PP), polystyrene (PS) or polyethylene terephthalate (PETP) 
  • Specifies a list of 12 specific plastic containers, and plastic containers for milk and milk products, under List Number 1, to conform to the following:
    • Specific migration of 20 heavy metals (Table 1 of List Number 1, see also Table 1 below)
    • ≤ 10 mg/dm2 for overall migration (Table 2 of List Number 1)
    • ≤ 0.002 mg/kgfor the specific migration of each of the 22 primary aromatic amines (PAAs, Item 1 to Table 3 of List Number 1)
    • ≤ 0.002 mg/kg for the specific migration of 1, 3-phenylenediamine (1,3-diaminobenzene, CAS 108-45-2, Item 2 to Table 3 of List Number 1)
    • The list of PAAs falling under Table 1 to Annex I of Regulation (EU) 10/2011  ‘Union list of authorized monomers, other starting substances, macromolecules obtained from microbial additives and polymer production aids,’, as amended (Item 3 to Table 3 of List Number 1) 
    • ≤ 0.002 mg/kg for the specific migration of each PAA and ≤ 0.01 mg/kg for the sum of PAAs, other than PAAs in the aforementioned Items 1-3 to Table 3 of List Number 1)
  • Requires specific plastics to conform to the specific migration of certain substances/entries of substances:
    • Polyvinyl chloride (PVC, 1 substance)
    • Polyvinylidene chloride (PVDC, 1)
    • Polycarbonate (PC, 3)
    • Nylon/polyamide (Nylon/PA, 1)
    • Polymethyl methacrylate (PMMA, 1)
    • Melamine (3)
    • Polyethylene terephthalate (PETP, 28)
  • Defines safety assessment documentation requirements for plastic containers that are not within the scope of the list of 12 types of plastic, and plastic containers for milk and dairy products, under List Number 1
  • Prohibits plastic containers as food contact plastic articles if these have been used to package fertilizers or other hazardous substances.

Highlights of the specific migration of 20 heavy metals from the draft Notification are summarized in Table 1.

WTO Document Number 22-0680, January 27, 2022
Draft Ministry of Public Health Notification ‘Determination of Quality or Standards for Plastic Containers’
Table 1 to List Number 1 (as per draft Notification) ‘Specific Migration of Heavy Metals’



Scope of Plastic

Specific Migration Limit 
(SML, mg/kg)


 Aluminum (Al)

  • Melamine

  • Nylon (PA)

  • Polycarbonate (PC) 

  • Polyvinyl chloride (PVC)

  • Polyethylene (PE)

  • Polyethylene terephthalate (PETP)

  • Polymethyl methacrylate (PMMA)

  • Polymethylpentene (PMP)

  • Polypropylene (PP)

  • Polystyrene (PS)

  • Polyvinyl alcohol (PVA)

  • Polyvinylidene chloride (PVDC) 

  • Plastic containers for milk or dairy products*



 Antimony (Sb)



 Arsenic (As)

 ND (DL = 0.01)


 Barium (Ba)



 Cadmium (Cd)

 ND (DL = 0.002)


 Cobalt (Co)



 Copper (Cu)



 Chromium (Cr)

 ND (DL = 0.01)


 Germanium (Ge)



 Lead (Pb)

 ND (DL = 0.01)


 Iron (Fe)



 Lithium (Li)



 Manganese (Mn)



 Mercury (Hg)

 ND (DL = 0.01)


 Nickel (Ni)



 Zinc (Zn)



 Europium (Eu)

 0.05 (sum)


 Gadolinium (Gd)


 Lanthanum (La)


 Terbium (Tb)

*Plastic containers made from 1) polyethylene (PE), 2) ethylene 1-alkene copolymerized resin, 3) polypropylene (PP), 4) polystyrene (PS) or 5) polyethylene terephthalate (PETP)

Table 1

Thailand’s draft notification is proposed to repeal Notification of the Ministry of Public Health (No. 295) B.E. 2548 (2005) and to enter into force on the day after its publication in the Government Gazette.

According to the draft notification, food contact materials and articles made from virgin plastic that were in use prior to this notification may continue to be used for no more than three years from the date of entry into force.

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. In the end, it’s only trusted because it’s tested. Discover more on our website and read our brochure.

For inquiries, please contact:

Dr. Hingwo Tsang
Global Information and Innovation Manager
t: (+852) 2774 7420

Rutchuporn Moungsom
Hardlines/Toys Laboratory Manager
t: +66 2 294 7485

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