Georgia Announces Legislation on Food Contact Plastics

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)