Thailand Proposes Revisions to Food Contact Plastic Packaging Rules

SG 132/26

Thailand proposes updates to plastic food contact material requirements.

On September 16, 2026, Thailand’s Food and Drug Administration (TFDA) opened a consultation on proposed amendments to the Notification of the Ministry of Public Health (MoPH No. 435) B.E. 2565 (2022), issued under the Food Act, B.E. 2522 (1979), on food contact plastic packaging. The proposal would revise requirements for permitted plastics, recycled materials and certain substances used in food contact plastic containers.

What does this proposal require?

Key changes include:

• Introducing seven new types of plastic and requirements for containers made from virgin plastic that are not currently specified in MoPH No. 435 but are authorized for use, including ethylene-vinyl acetate-vinyl alcohol copolymer (EVOH), polylactic acid (PLA), polybutylene succinate (PBS), polybutylene succinate adipate (PBSA) and polyphenylene oxide (PPO).
• Removing certain plastics used for the manufacture of containers, specifically polycarbonate (PC), or permitting their continued use but subject to stricter migration limits:
  • Approach one would remove PC from Annex 1 to MoPH No. 435, with a five-year transition for compliance after the date of entry into force of the notification, and require all plastic containers to demonstrate that bisphenol A (BPA) is not detected, based on an extraction method with a detection limit (DL) of 1 µg/kg.
  • Approach two would continue to permit the use of PC plastics but with stricter migration requirements, under which BPA and its salts must not migrate into food at a DL of 1 µg/kg, subject to specified exceptions in Regulations (EU) 2024/3190 and (EU) 2026/250 (SafeGuardS 19/26 and references therein).
• Adding a section for plastic containers made from recycled high-density polyethylene (rHDPE) pellets, with detailed principles and rules for authorization.
• Enhancing quality requirements or standards for certain types of plastic:
  • Establishing requirements for plastic containers manufactured using epoxy derivatives by implementing provisions from Regulation (EC) No. 1895/2005 on the restriction of the use of certain epoxy derivatives in food contact materials and articles.
  • Introducing per- and polyfluoroalkyl substances (PFAS) standards for plastic containers using the analytical stepwise approach for PFAS limits in food contact packaging materials under Commission Notice C/2026/3084 (Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste, PPWR).
  • Updating SMLs of substances for containers made from polyolefins and other plastics, including but not limited to BPA and several phthalates (BBP, DAP, DBP, DEHP, DIBP, DIDP and DINP).

Abbreviations

Who is impacted?

The proposed amendments would affect stakeholders across the food contact plastic materials and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in Thailand.

When is the deadline for comments?

Comments on the proposal will be accepted until December 31, 2026.

We provide comprehensive FCM testing, including migration tests, along with expert guidance on evolving regulations, compliance issues and documentation review. Our expertise ensures your products meet the appropriate territorial regulations for food contact materials and helps pave the way for compliance. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.