Thailand Food Contact Materials Regulations

1. Definition

Food contact materials (FCM) refer to materials and products that are already or expected to be in contact with food under normal conditions of use. In Thailand, it includes plastic food packaging, ceramic/enameled metal vessel, feeding bottles, etc.

2. Competent authorities

Competent authority	Responsibility
Thailand Food and Drug Administration (TFDA)	Formulating relevant regulations, as well as the monitoring, supervision, and inspection of FCM products
Thailand Industrial Standards Institute (TISI)	Drafting the FCM standards; taking charge of product certification
Department of Science Service (DSS)	Conducting testing and safety assessment of FCM
Ministry of Commerce (MOC)	Taking charge of the imported ceramic and enameled metal vessel
Office of the Consumer Protection Board (OCPB)	Regulating the label of plastic packaging

3. Market access requirements

3.1 Import permit

Food Act B.E. 2522 is the fundamental law of food contact materials in Thailand. According to the Act, FCM importers whose companies based in Thailand should obtain an import license for the products they intend to import, and register for the serial number from Food and Drug Administration (FDA) themselves. Apart from that, importers should register with the Thai Customs for the customs clearance procedures.

3.2 Health certificate

According to Notification of the Ministry of Commerce Re: Ceramic Containers and Enameled Metal Containers Used for Food Packaging, imported ceramic and enameled metal containers should be attached with health certificate to showcase the migration level of lead and cadmium in the containers. The certificate is issued by the agency or institution certified by the authority of the country of production.

4. Product compliance

Thailand authority has stipulated the quality requirements of ceramic containers, enameled metal containers, and plastic packaging. In addition, there is a regulation exclusive for feeding bottles and milk containers for infants and young children. In principle, the food containers shall be clean, without harmful substances and contamination. Please refer to the following regulations for the detailed requirements.

Food containers	Referenced regulation	Notes
Plastic containers	MOPH Notification No. 435 B.E. 2022 Re: Determination of Quality or Standards of Plastic Containers	The Notification specifies the migration limits and quality requirements for plastic packaging. Plastic packaging used to contain milk and milk products must be the plastic of polyethylene, ethylene 1-alkene copolymerized resin, polypropylene, polystyrene, or polyethylene terephthalate. Recycled plastics are subject to additional requirements. For example, safety assessment is required for packaging made from secondary-recycled plastic.
Ceramic and enameled metal containers	MOPH Notification No. 92 Re: Prescription of Quality or Standard for Food Containers, Use of Food Containers, and Prohibition of Use of Things as Food Containers	Migration limits are specified.
Feeding bottles and milk containers for infants and young children	MOPH notification No. 369: Feeding Bottles and Milk Containers for Infants and Young Children	Quality requirements, permitted materials and migration levels are specified.

5. Label

According to the Notification No. 9 (2001) -Plastic Packaging Labeling issued by OCPB, plastic products are label-controlled, and should be indicated with “Instructions for use” and “Caution”. The following table lists some situations and their corresponding caution statement.

Situations	Statement
The plastic products are not for food-contact use.	“Do not use to pack or wrap food”
The product cannot be used at over 95 degrees Celsius.	“Prohibiting for hot food”
When the products can support heavyweight such as table, chair, and stair.	“Bearing capacity not over ... kilograms or kgs”
The product is made from recycled plastic.	“Containing some recycled material”

Please note that the caution content requires a larger font than other texts.

In 2004, OCPB issued Notification No. 18 (2004) -Labelling of Melamine Formaldehyde, stating that melamine container and packaging are label-controlled goods as well. The product shall be labeled with “Instructions for use” and “Caution”, with “Do not use for containing food or liquid over 100 degrees Celsius” for the Caution part.