Brazil has revised several pieces of legislation on food contact materials and articles. These will become effective on January 3, 2023.

SAFEGUARDS | HardgoodsNO. 028/22

 SG 15521 Plastic Containers

In December 2021, Brazil’s Ministry of Health/National Health Surveillance Agency (Ministério da Saúde/Agência Nacional de Vigilância Sanitária (ANVISA)) published Resolution of the Collegiate Board of Directors No. 589 of December 20, 2021 (Resolução de Diretoria Colegiada RDC No. 589, de 20 de dezembro de 2021, 589/2021) to transpose GMC/Mercosur Resolution Nos. 19/2021, 20/2021 and 21/2021 into national law on food contact materials and articles. 

The latest transposition revises three pieces of national legislation on food contact materials and articles:

Highlights of major changes to these three resolutions are summarized in Table 1.

Resolution RDC No. 589 of December 20, 2021
Official Journal of the Union, December 22, 2021, page 298


Highlights of Major Changes

Resolution No. 105 of 1999 ‘General provisions for food contact plastics’

  • Amends the requirements for overall migration:

    • ≤ 10 mg/dm², otherwise ≤ 60 mg/kg for plastic containers and equipment with a defined volume or plastic containers and equipment intended to come into contact with food for infants and children under three years of age

    • ≤ 60 mg/kg for containers with closure systems such as lids, gaskets and stoppers if intended use is known, otherwise the unit is in mg/article if the intended use of the article is unknown

  • New requirements for coatings that are applied on containers with a volume of a) less than 25 L, b) equal to or greater than 25 L but no more than 10,000 L and c) greater than 10, 000 L 

  • ≤ 60 mg/kg for coatings applied to pipes or hoses 

Resolution of the Collegiate Board of Directors – RDC No. 56 of 2012 ‘Positive list for food contact plastics’

  • ≤ 0.01 mg/kg for sum of specific migration (SM) of primary aromatic amines, (PAA) other than those in Parts I to Annex ‘List of monomers and other authorized starting substances’ and V ‘‘Authorized Polymers’ to Resolution RDC 589/2021 and Resolution RDC 326/2019 (SafeGuardS 84/20 and references therein) 

  • Adds several substances to Part I of the Annex

  • Amends the restrictions and/or specifications for 11 substances in Part I to Annex, including:

    • ≤ 0.05 mg/kg for the SM of bisphenol A (BPA)

    • Prohibiting BPA in feeding bottles and similar articles for infants and children up to three years of age

    • ≤ 3 mg/kg for SM of phenol

  • Revises ‘Table: Notes on the column ‘Restrictions and/or Specifications’ (Part IV to Annex), including new entries 25 and 26

  • Adds ethylene-vinyl alcohol modified with 2-methylene-1,3-propanediol (number 1485481-35-3) with restrictions to Part V of Annex 

Resolution of the Collegiate Board of Directors – RDC No. 88 of 2016 ‘Food contact cellulosic materials and articles

  • Adds three entries and amends one entry to the positive list, all with specifications (Part II to Annex)

Table 1

The new resolution entered into force on January 3, 2022 and the provisions will become effective on January 3, 2023.

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.   

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