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Georgia Announces Legislation on Food Contact Plastics

SafeGuardSHardgoodsNovember 07, 2022

SG 126.22

Georgia has issued a Technical Regulation on plastic materials and articles intended for contact with food based on the EU food contact plastics regulation. The Technical Regulation will become effective on January 1, 2026.

In June 2022, Georgia issued Resolution No. 304 of June 8, 2022 (Resolution No. 304/2022) approving the nation’s Technical Regulation on plastic materials and products (articles) intended to come into contact with food. The new law is essentially based on Regulation (EU) 10/2011, with amendments to Regulation (EU) 2020/1245, in the European Union (consolidated version to September 2020) on food contact plastics (SafeGuardS 134/20).

Highlights of Resolution No. 304/2022 are summarized in Table 1.

Resolution No. 304 of June 8, 2022, Regarding the Approval of the Technical Regulation on Plastic Materials and Products (Articles) Intended to Come into Contact with Food, Government of Georgia, June 10, 2022

Section

Highlight

Article 2 ‘Purpose and Scope’

  • Establishes requirements for the manufacture and placing on the market of plastic materials and articles that are:

    • Intended to come into contact with food

    • Already in contact with food, or

    • Reasonably expected to come into contact with food

  • Excludes the following materials from the scope:

    • Ion exchange resins
    • Rubber
    • Silicones

Article 5 ‘Authorized Substances‘

  • Food contact plastics must only be manufactured using the authorized list of substances in Annex 1 (positive List)

Article 7 ‘Specific Requirements for Substances’

  • Substances used in the manufacture of plastic layers in plastic materials and articles must respect the specific migration and overall migration limits, as well as any substance restrictions and specifications, including those falling under Table 1 to Annex 1 (Positive List)

Article 8 ‘General Restrictions on Plastic Materials and Articles’

  • Plastic materials and articles must comply with the specific migration limit for 19 substances, and an additional 5 substances where their migrations are subject to Articles 9(2) and 10 in the Technical Regulation (Annex 2)

  • ≤ 0.002 mg/kg for each primary aromatic amine (PAA) where there is no migration limit in Table 1 to Annex 1

  • ≤ 0.01 mg/kg for the sum of PAA not listed in Table 1 to Annex 1 for compliance with general safety requirements (Article 4 to Resolution No. 317/2018)

Article 9 ‘Specific Migration Limit’

  •  Substances must conform to specifications in Annex 1

  •  A detection limit of 0.01 mg/kg applies to substances or groups of substances where migration is not permitted

Article 10 ‘Overall Migration Limit’

  • ≤ 10 mg/dm², otherwise ≤ 60 mg/kg for food contact plastics intended to be brought into contact with food intended for infants and young children

Annex 1 ‘Authorized monomers, other starting substances, macromolecules obtained from microbial fermentation, additives and polymer production aids’

Contains several Tables:

  • Table 1 ‘Authorized substances for the manufacture of plastic materials and articles‘ has more than 1,000 FCM entries
  • Table 2 ‘Group restriction of substances‘
  • Table 3 ‘Notes on Verification of compliance‘
  • Table 4 ‘Detailed specifications on substances‘

Annex 2 ‘Restrictions on Plastic Materials and Articles’

  • Table 5 details the migration specifications for 24 substances

 Annex 3 ‘Food Simulants’

  • Table 6 specifies the list of food simulants

  • Table 7 summarizes the assignment of food simulants to different categories of food

  • Table 8 details food simulant assignments for demonstrating compliance with overall migration limits

Annex 4 ‘Declaration of Compliance’

  • Details the information required in the written declaration

 Annex 5 ‘Compliance Testing’

  • Indicates the testing procedures for specific migration of materials and articles that are either already in contact with food or not yet in contact with food

  • Details the selection of testing conditions (Tables 9 for time and 10 for temperature) and specific conditions for contact times for more than 30 days at room temperature and below

  • Details the verification and compliance requirements for repeated use materials and articles, including the stability of the material from the first to third migration tests

  • Table 11 details the standardized conditions for testing overall migration (OM 0 to OM 7)

  • Table 12 details substitute overall migration tests (OM 8 and OM 9) for tests using vegetable oil (food simulant D2)

Table 1

Resolution No. 304/2022 on food contact plastics will become effective on January 1, 2026.

In 2018, Georgia issued Resolution No. 317/2018 on requirements for materials and articles intended for contact with food. This ‘Framework Regulation’, modeled on Regulation (EC) 1935/2004 in the European Union, established 17 groups of food contact materials and articles which may be covered by specific measures, as well as requirements for active and intelligent materials and articles. The law contains requirements for, inter alia, authorization of new substances, confidentiality, declaration of compliance (DoC), economic operators, general safety (Article 4), groups of materials and articles, labeling (which includes the glass and fork symbol) and traceability.

Since its publication, Resolution No. 317/2018 has been amended twice:

  • Resolution No. 120/2020 in relation to rules for good manufacturing practice (GMP) and a quality assurance system for food contact recycled plastics
  • Resolution No. 112/2021 in relation to vinyl chloride monomer in materials and articles made with vinyl chloride polymers or co-polymers (≤ 1.0 mg/kg vinyl chloride in the final product and ≤ 0.01 mg/kg for the specific migration of vinyl chloride) 

Resolution No. 317/2018 will become effective on September 1, 2024. 

For enquiries, please contact:

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

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