SG 05/24
Indonesia has published a draft piece of legislation to set compliance requirements for food contact materials and articles. If approved, the new law will enter into force on the day of its promulgation.
In October 2023, Indonesia’s Agency for Food and Drug Control (Badan Pengawas Obat dan Makanan, BPOM) initiated a consultation over the nation’s draft regulation on food contact materials (FCM) and articles.
The draft regulation contains important provisions for various types of FCM and articles. It:
- Defines the scope of FCM:
- Ceramics
- Glass
- Plastics
- Metals and metal alloys
- Multilayer materials
- Paper and carboards
- Rubber and elastomers
- Permits the use of recycled materials – the provisions for FCM and food contact substances will apply mutatis mutandis to these materials
- Requires the aforementioned categories (and sub-categories) of FCM to comply with specific requirements for overall migration (OM) and specific migration (SM) (Appendix I)
- Details the testing conditions for OM and SM, including time, temperature and simulants (Appendix II)
- Permits more than 1,300 entries of substances, with specifications, to be used for FCM (positive list, Appendix III)
- Prohibits more than 140 entries of substances from being used in FCM (Appendix IV)
Highlights of the general requirements in the draft regulation for food contact plastics are summarized in Table 1.
Draft Regulation of the Drug and Food Regulatory Agency, October 2023
Section A.I. to Appendix I ‘General requirements for all types of food contact plastics’
| Item | Parameter | Maximum limit |
|---|---|---|
| 1 | Overall migration | 60 mg/kg or 10 mg/dm2 |
| 2 | Specific migration of arsenic | Not detected (LOD = 0.01 mg/kg) |
| 3 | Specific migration of cadmium | Not detected (LOD = 0.002 mg/kg) |
| 4 | Specific migration of (total) chromium | Not detected (LOD = 0.01 mg/kg) |
| 5 | Specific migration of lead | Not detected (LOD = 0.05 mg/kg) |
| 6 | Specific migration of mercury | Not detected (LOD = 0.01 mg/kg) |
Table 1
Comments were accepted until December 2023.
If approved, the draft regulation will enter into force on the date of promulgation and repeal Regulation No. 20 of 2019 on Food Packaging (Peraturan BPOM Nomor 20 Tahun 2019 Tentang Kemasan Pangan).
FCM and articles are obliged to comply with the provisions in the new law no later than 12 months after the draft regulation is promulgated.
SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials, paving the way for compliance. From overall migration tests to expert advice on emerging regulations, compliance issues and documentation review, SGS is the partner to trust. Discover more on our website. In the end, it’s only trusted because it’s tested.
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