In December 2023, Indonesia food and drug administration (BPOM) revealed the draft of food packaging regulation. Once the draft is approved, enterprises must adjust the packaging of their food products within 12 months.
The proposed draft covers the requirements for food packaging materials, food contact substances, recycled packaging, and testing. In the annexes, the draft lists the permitted food packaging materials, including seven kinds, namely, plastic, rubber and elastomer, paper and carton, ceramic, glass, metals and metal alloys, and multilayer. Requirements for migration and extraction testing of these materials are also clarified. In addition, it lists the food contact substances permitted/prohibited for use as food packaging.
Annex 1 Permitted Food Packaging Materials
Annex 1 lists the requirements for seven kinds of permitted food packaging materials. Take plastic for an example, the annex specifies the general requirements which apply to all types of plastic materials, and additional requirements for 54 types of plastic materials, such as acrylonitrile/styrene copolymer (No. CAS: 9003-54-7).
General requirements for plastic
Item | Maximum limit |
Total migration | 60 mg/kg or 10 mg/dm2 |
Specific heavy metal migration | |
Arsenic | Not detected (LOD 0.01 mg/kg) |
Cadmium | Not detected (LOD 0.002 mg/kg) |
Total chromium | Not detected (LOD 0.01 mg/kg) |
Lead | 0.05 mg/kg |
Mercury | Not detected (LOD 0.01 mg/kg) |
Additional requirements for acrylonitrile/styrene copolymer
Item | Maximum limit |
Acrylonitrile | Not detected (LOD 0.01 mg/kg) |
Styrene | 60 mg/kg |
Annex 2 Food Packaging Migration Testing
Annex 2 details six kinds of testing of food packaging materials, including:
1. Total migration testing of plastic, multilayer and metal food packaging materials (replaced as food packaging materials);
2. Specific migration and heavy metal testing of plastic and elastomer food packaging materials;
3. Total and specific migration testing of plastic food packaging materials intended for reuse;
4. Extraction testing of plastic and paper food packaging materials;
5. Specific migration testing of rubber food packaging materials (elastomers);
6. Specific migration testing of ceramic and glass food packaging materials.
Annex 3 Food Contact Substances Permitted For Use As Food Packaging
Annex 3 divides all the permitted food contact substances into two categories, including 115 substances with migration limit restrictions and 1,372 substances without migration limit restrictions.
Permitted food contact substances with migration limit restrictions (excerpt)
Name | CAS No. | Types of Food Packaging Materials | Function | Migration restrictions | |||||
Plastic | Rubber-Elastomer | Metal | Paper and Cardboard | Glass | Ceramic | ||||
1-(2-Butoxy-1-methylethoxy)-2- propanol | 29911-28-2 | √ | √ | √ | √ | √ | √ | Solvent | 0.05 mg/kg |
1,1,1- trimethylolpropane | 77-99-6 | √ | √ | √ | √ | √ | √ | Adhesive | 6 mg/kg |
Permitted food contact substances without migration limit restrictions (excerpt)
Name | CAS No. | Types of Food Packaging Materials | Function | |||||
Plastic | Rubber-Elastomer | Metal | Paper and Cardboard | Glass | Ceramic | |||
((1,2,5,6-eta.) -1,5- cyclooctadiene) bis((4- (trimethylsilyl) phenyl)ethunyl)-platinum | √ | √ | Modifier | |||||
(2-Alkenyl) succinic anhydrides in which the alkenul groups | √ | Others | ||||||
Annex 4 Food Contact Substances Prohibited For Use As Food Packaging
Annex 4 lists 142 substances that are prohibited to be used in food packaging.
Prohibited food contact substances to be used in food packaging (excerpt)
Name | CAS No. |
1, 1, 1-Trichloroethane | 71-55-6 |
1, 1,2,2-Tetrachloroethane | 79-34-5 |
Annex 5 Example Of Application Form For The Use Of Food Packaging Materials
As per the draft, for food packaging materials and food contact substances outside of this draft, as well as food packaging materials with the claim of being easily degradable in environment, enterprises are required to apply for a safety review from BPOM.
Annex 5 provides the example of application form. Each application must include the following information: a) information of the applicant; b) data of the food packaging material and/or food contact substance; c) laboratory test results of the food packaging.
For the full English version of this drafted regulation, please feel free to contact us.
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