Indonesia’s Food and Drug Authority (BPOM) a draft regulation on food contact materials (FCMs) in October 2023. The final version will be published sometime in 2024 and come into force one year after publication.
The draft regulation slightly reorganizes the categories of FCMs in Indonesian regulation. In the current regulation, which came into force in 2020, printing inks and coatings are an FCM category the same level as, for example, plastics or glass (FPF reported). In the proposed update, printing inks and coatings are no longer a separate FCM category. Even without these two categories, BPOM has expanded the covered material types, and components like ink, coating, adhesive, and other functions are now highlighted chemical-by-chemical in lists in the annex.
The material groups are:
- Plastics
- Rubber and elastomers
- Paper and board
- Ceramics
- Glass
- Metal and metal alloys
- Multilayer materials
Each material type has general migration requirements with special requirements by sub-type. For example, all plastic materials have a general migration limit of 60 mg/kg while specific polymers have special migration limits for starting substances or applicable chemicals of concern. Some examples:
- Melamine-formaldehyde resin (melamine) has maximum migration limits for both starting substances, 2.5 and 3 mg/kg, respectively. Plus, the added limitation that it is not to be used in microwaveable containers.
- Polyethylene terephthalate (PET) has migration limits for ethylene glycol (CAS 107-21-1), diethylene glycol (CAS 111-46-6), acetaldehyde (CAS 75-07-0), terephthalic acid (CAS 100-21-0), isophthalic acid (121-91-5, and antimony trioxide (CAS 1309-64-4)
- While polylactic acid (PLA) and polypropylene (PP) have no special requirements and substances are subject to the general 60mg/kg for plastics
The FCM migration testing guidelines included in the draft consider the type of packaged or processed food (e.g., dairy, baked goods) and the “worst case” contact time and temperature between the material and food item.
The draft regulation includes a set of annexes with lists of chemicals, the materials they are known to be used in, their function, and migration limit. These annexes include: (i) 115 permitted substances with migration limits; (ii) 1372 permitted substances without a specific migration limit; and (iii) 142 substances prohibited for use. The prohibited substances list also applies to components of a food contact article including inks, dyes, adhesives, etc.
For other policy updates expected in the coming year, review FPF’s 2024 policy outlook as well as the consultations page.
Reference
BPOM (October 31, 2023). “.” (in Indonesian)
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