Indonesia Consults Over Draft Law on Food Packaging

SafeGuardSHardgoodsDecember 12, 2024

SG 171/24

Indonesia has informed the World Trade Organization (WTO) of its draft regulation on food contact materials and articles. Comments are being accepted until January 27, 2025.

In November 2024, the WTO announced a draft piece of legislation from Indonesia’s Food and Drug Authority (Badan Pengawas Obat dan Makanan (BPOM)) on food packaging materials (FPM).

Highlights of the proposed law, attached to WTO document number 24-8412, are summarized in Table 1.

Section to Draft Regulation	Highlights
Chapter II ‘Food Packaging Materials’	Scope of FPM: Ceramics Glass Metals and alloys Multilayer materials Paper and cardboards Plastics Rubber and elastomers The FPM above must meet overall migration (OM) and/or specific migration (SM) requirements (Appendixes I-V)
Chapter III ‘Food Contact Substances’	Permits food contact substances (FCS) in Appendix IV to be used in food packaging
Chapter IV ‘Food Packaging from Recycled Materials’	The provisions for FPM apply mutatis mutandis to recycled materials
Chapter V ‘Assessment’	FPM and/or FCS other than those listed in Appendices I and IV may only be permitted to be used upon approval from the Head of the Agency based on safety assessment (see Appendix VI for example of ‘Request Form for Assessment’) The above point also applies to materials that are readily decomposed in the environment
Chapter V ‘Transitional Provisions’	Food packaging in circulation must comply with the new law within 12 months from the day the legislation is enacted
Chapter VI ‘Closing Provisions’	Repeals Regulation No. 20 of 2019 on Food Packaging on the day the new law enters into force The new law enters into force on the date of promulgation
Appendix I ‘Migration Limit Requirements for FPM’	Establishes a set of general requirements for food contact plastics: ≤ 60 mg/kg or 10 mg/dm² for OM Not detected (ND) for SM of each of arsenic, total chromium and mercury (LOD 0.01 mg/kg) ND for SM of cadmium (LOD 0.002 mg/kg) ≤ 05 mg/kg for SM of lead Defines specific requirements for SM of 55 different types of plastic Details general requirements for food contact rubber and elastomeric materials Describes SM requirements for 23 types of rubber and elastomer ≤ 0.01 mg/kg N-nitrosamines and ≤ 0.1 mg/kg N-nitrosatable substances for food contact rubber and/or elastomers intended for infants/children Sets forth OM and heavy metal content limits for uncoated paper and cardboards according to SNI 8218:2015 ‘Paper and cardboards for food packaging’ or the latest and most recent provisions Sets out migration of lead and cadmium requirements for food contact glass and ceramics Details general requirements for extractable lead and cadmium in metals and alloys Defines SM requirements for specific types of metal and alloy Defines requirements for multilayer materials
Appendix II ‘Migration Testing’	Describes methods for migration testing
Appendix III ‘Overall Migration and Specific Migration Testing of Plastic FPM Intended for Reuse’	Details migration testing for repeated use food contact plastics
Appendix IV ‘Food Contact Substances Permitted for use as Food Packaging’	A positive list containing more than 1,300 entries of authorized substances with specifications for food contact use
Appendix V ‘Food Contact Substances Prohibited for use as Food Packaging’	Prohibits 142 substances in FCP
Appendix VI ‘Example of Request Form for Assessment’	Provides an example of an application form for the safety of food packaging

Table 1

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