Uganda Proposes New Standard for Food Contact Materials and Articles

SafeGuardSHardgoodsJuly 19, 2022

SG 086.22

Uganda has informed the WTO of its intention to publish a new standard for food contact materials and articles.

On June 22, 2022, the World Trade Organization (WTO) announced a draft standard from Uganda’s National Bureau of Standards on its intention to set out new requirements for food contact materials and articles.

The draft standard, attached to WTO document number 22-4853 and notified under G/TBT/N/UGA/1610, contains several important requirements. It:

Requires food contact surfaces and the materials, including active and intelligent materials, used for manufacturing to be in accordance with Good Manufacturing Practices (GMP) and meet general safety requirements
Specifies food grade raw materials and colorants to be used for manufacturing
Requires printing inks applied to the non-food contact side of materials and articles not to transfer substances from the printed surface
Requires food contact materials and articles not to transfer their constituents to food in quantities exceeding overall migration and/or specific migration limits (see Table 1 below)
Requires food contact packaging materials to be manufactured and handled in a hygienic manner, and in accordance with US ISO/TS 22002-4 ‘Pre-requisite programs on food safety – Part 4: Food packaging manufacturing’
Details labeling requirements on each consignment and or packing slips are specified, including the words ‘for food contact use’ or the glass and fork symbol (Section 8)
Indicates that products conforming to Uganda standards may be marked with the Uganda National Bureau of Standards (UNBS) Certification Mark

Highlights of Section 4.7 ‘Migration’ in the proposed standard are summarized in Table 1.

Draft Uganda Standard DUS 1659 Second Edition 2022-mm-dd Section 4.7 ‘Migration’ (per standard text)
Section/Title	Highlight
4.7.2 ‘Plastic materials’	≤ 60 mg/kg overall migration according to US 1675, otherwise ≤ 10 mg/dm² for the following: Articles with a capacity of less than 500 mL or more than 10 L Sheets, films or other materials and articles which cannot be filled or where it is impractical to measure the relationship between the surface area of such material or article and the quantity of food in contact therewith
4.7.3 ‘Metals and alloys’	Conform to the specific migration of 20 metals using ISO 16918 (see Table 2 below)
4.7.4 ‘Glass Containers’	≤ 0.5 mg/kg lead and ≤ 0.25 mg/kg cadmium using ISO 7086-1 ‘Glass hollowware in contact with food – Release of lead and cadmium – Part 1: Test method’
4.7.5 ‘Ceramic packaging materials’	Conform to the migration of lead and cadmium (See Table 3 below)
4.7.6 ‘Active and intelligent materials and articles’	Conform to general safety

Table 1

Draft Uganda Standard DUS 1659 Second Edition 2022-mm-dd Section 4.7.3.1, Table 1. Maximum release limits for heavy metals in metals and alloys for food contact use (per standard text)
Entry	Metal	Limit (mg/kg)	Entry	Metal	Limit (mg/kg)
1	Aluminum	5	11	Lithium	0.048
2	Antimony	0.04	12	Manganese	1.8
3	Arsenic	0.002	13	Mercury	0.003
4	Barium	1.2	14	Molybdenum	0.12
5	Beryllium	0.01	15	Nickel	0.14
6	Cadmium	0.005	16	Silver	0.08
7	Chromium	0.25	17	Thallium	0.0001
8	Cobalt	0.02	18	Tin	100
9	Iron	40	19	Vanadium	0.01
10	Lead	0.01	20	Zinc	5

Table 2

Draft Uganda Standard DUS 1659 Second Edition 2022-mm-ddSection 4.7.5, Table 1. Permissible limits for lead and cadmium for ceramic items intended to come into contact with food using ISO 6486-1 (per standard text)
Category	Scope	Permissible limit
Category	Scope	Lead	Cadmium
1	PASS	0.8 mg/dm²	0.07 mg/dm²
2	All other articles which can be filled	4 mg/L	0.3 mg/L
3	Articles having a capacity of more than 3L	1.5 mg/L	0.1 mg/L

Table 3

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.

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Dr. Hingwo Tsang
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