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The rules governing food contact materials (FCM) in the Asia-Pacific Region are jurisdiction dependent.

Although a ‘common market’ approach is gaining momentum in this region since India, South-Korea, Japan, Australia and New-Zealand approached the ASEAN Free Trade Area (AFTA), the requirements for general safety are essentially similar to other international markets such as Europe, North America and Mercosur. 

General Safety Requirements

As part of the general safety requirements, the quantity of substances transferred from FCM and articles (FCA) to food must not endanger human health or bring about unacceptable changes to the composition of food such as taste and odor.

Diversity & Complexity

The requirements in the Asia Pacific Region are highly complex and diverse. Some countries/regions, such as Hong Kong and the Philippines, recognize demonstration of compliance to requirements from the US FDA, whereas some countries such as China, Japan and South Korea require conformity assessment procedures to be carried out from approved laboratories for formal acceptance.

General Laws and/or Standards for Key Countries in this Important Region

Jurisdiction Legislation/standard
  • Australia and New Zealand Food Standards Code, Standard 3.2.2 ‘Food Safety Practices – General Requirements’
  • Regulations 4E ‘Importation of Glazed Ceramicware’
  • AS 2070 ‘Plastics’
  • Presidential Decree No. 21 ‘Food Safety Law of the People's Republic of China’
  • GB 4806.1-2016 (General Safety Requirements for food contact materials and articles) and a corresponding series of mandatory standards for products and test methods
Hong Kong Public Health and Municipal Services Ordinance, Chapter 132
India The Food Safety and Standards Act of 2006 (FSSA, No. 34 of 2006)
  • Food Law 18/2012
  • National Agency of Drug and Food Control (BPOM) Regulation No. HK.
  • Act No. 233 of 24 December, 1947 ‘Japan Food Sanitation Act / Japan Food Sanitation Law (JFSL)’- Chapter III ‘Apparatus, Containers and Packaging’
  • Specifications and Standards for Foods, Food Additives etc. under the Food Sanitation Act
Malaysia Food Regulations of 1985 (P.U. (A) 437/1985), Part VI ‘Packages for food’
Philippines Republic Act No. 10611 (Food Safety Act of 2013)
Singapore Food Regulations under the Sale of Food Act, 1973 (revised 2002)
South Korea
  • Food Sanitation Act
  • Korea Standards and Specifications for Utensils, Containers and Packaging for Food Products (Chapter 7 of the Korean Food Code)
  • Act Governing Food Sanitation (the Act)
  • Sanitary Standard for Food Utensils, Containers and Packages
  • Food Act, B.E. 2522 (1979)
  • Ministerial Notification No. 295, B.E. 2548 (2005) for plastics
  • Food Safety Law (No. 55/2010/QH12)
  • Technical standards/Regulations including QCVN 12-1:2011/BYT ‘Plastics’

Specific Measures Affecting Bisphenol A (BPA)

Similar to many jurisdictions around the world, many countries in this region restrict or prohibit the use of BPA in FCM and FCA. This includes, but is not limited to China, Japan, Malaysia and South Korea. In Australia, certain major retailers have voluntarily phased-out the use of BPA in polycarbonate plastic feeding bottles.

Jurisdiction Citation Scope Requirement
Australia Announcement by Parliament Secretary for Health
Media Release, 30 June, 2010
Baby bottles Voluntary phase out by certain major retailers
China Ministry of Health, Bulletin No. 15 of 2011 Polycarbonate baby feeding bottles and other infant feeding bottles Prohibited
Japan Specifications for Food Additives, etc. under the Food Sanitation Act Food contact polycarbonate plastics ≤2.5 μg/mL migration (including phenol and p-tert-butylphenol)
Malaysia P.U. (A) 35/12 of the Food Regulations 1985 Feeding bottles Prohibited
South Korea Korea Food Code Section 7 Food contact polycarbonate plastics Prohibited

Developments in China

FCM and FCA in China are regulated by the ‘Food Safety Law of the People’s Republic of China’. On the basis of this piece of legislation, the National Health and Family Planning Commission (NHFPC) promulgated a series of new mandatory national standards for FCM and FCA between 2015 and 2016. These new standards reflect a major change from all previous standards, which have been revised, consolidated or otherwise changed.

The two most important 2016 versions of these standards are GB 4806.1 on general safety requirements and GB 9685 on the use of additives for FCM and products. These became effective in October 2017.

In addition, to ensure compliance with specifications in all related standards, economic operators placing FCM and FCA on China’s market are required to label their products properly and provide a declaration of compliance (DoC) according to section 8 of GB 4806.1-2016.

The Framework and Mandatory GB Standards

Asia Pacific Framework

China’s GB Standards for Food Contact Materials

Category Scope Standard
Basic Standard General Safety Requirements GB4806.1-2016
Additive GB9685-2016
Product Standard Rubber teat GB4806.2-2015
Enamel GB4806.3-2016
Ceramic GB4806.4-2016
Glass GB4806.5-2016
Plastic resin GB4806.6-2016
Plastic material and article GB4806.7-2016
Paper and paperboard GB4806.8-2016
Metal GB4806.9-2016
Paint and coating GB4806.10-2016
Rubber GB4806.11-2016
Determination Standard General principles of pre-treatment methods for migration test GB5009.156-2016
General principles for migration test GB31604.1-2015
Nine test method standards GB31604.2-2016 to
39 test method standards GB31604.11-2016 to

Food Safety Testing

SGS has the expertise to help manufacturers and suppliers of FCM achieve compliance with markets around the globe. Our technical experts have extensive experience of testing materials and articles for many markets. We offer the full range of FCM testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Our experience can ensure your products meet the appropriate territorial regulations for food contact materials and help pave the way for compliance.

Learn more about food contact testing services >