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Thailand Proposes to Mandate TIS 3206-2564 (2021) for Food Contact Stainless Steels

SafeGuardSHardgoods, Food Contact MaterialSeptember 15, 2022

SG 108.22

Thailand has informed the WTO of its intention to mandate TIS 3206-2564 (2021) for stainless Steel materials and articles intended to come into contact with food. This standard will become a legal requirement 270 days after publication in the Government Gazette.

On September 2, 2022, the World Trade Organization (WTO) announced a draft ministerial regulation from Thailand’s Ministry of Industry on its intention to mandate a specific safety standard for food contact stainless steel utensils.

The draft ministerial regulation, attached to WTO document 22-6570 and notified under G/TBT/A/THA/671, contains several important provisions. It:

  • Mandates TIS 3206-2564 (2021) ‘Stainless Steel Utensils for Food: Safety Requirement’ as the safety standard for stainless steel utensils used in households, restaurants and canteens, such as bowls, dishes, food trays, frying pans, pots and spoons or utensils with stainless steel as the main material/component in contact with food
  • Exempts stainless steel seamed stockpots (TIS 2440-2552 (2009)) and utensils used for storage or transportation, as well as tools used in non-thermal processing of food or slaughterhouse

TIS 3206-2564 (2021) directs the use of the following documents for analysis:

  • Chapter 3 of Metals and alloys used in food contact materials and articles, published by the European Directorate for the Quality of Medicines & Healthcare (EDQM) of the Council of Europe
  • Guidelines on testing conditions for articles in contact with foodstuffs (with a focus on kitchenware). A CRL-NRL-FCM Publication, 1st Edition [2009], by the European Commission Joint Research Center Institute for Health and Consumer Protection
  • Testing conditions for kitchenware articles in contact with foodstuffs: Plastics and Metals. The EURL-FCM harmonized approach series by the Joint Research Center (JRC), the European Commission’s science and knowledge service

Highlights of requirements for the specific migration of heavy metals in TIS 3206-2564 (2021) are summarized in Table 1

EntryHeavy MetalSpecific Release Limit (SRL, mg/kg food)
1Arsenic (As)0.002
2Cadmium (Cd)0.005
3Chromium (Cr)0.250
4Lead (Pb)0.010
5Manganese (Mn)1.8
6Nickel (Ni)0.14

Table 1.

According to the draft ministerial regulation, TIS 3206-2564 (2021) will become mandatory 270 days after its publication in the Government Gazette.

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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