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Thailand has issued proposals to introduce a mandatory standard for food contact materials and articles made from thermoset plastics derived from formaldehyde.

Circulated via the World Trade Organisation (WTO), the draft standard, designated TIS 2921-25XX(20XX), will cover the follow resins if adopted:

  • Melamine-formaldehyde (MF)
  • Melamine-urea-formaldehyde (MUF)
  • Urea-formaldehyde (UF)

Amongst other things, the draft standard covers:

  • Scope and definitions
  • Physical requirements
  • Requirements for:
    • Overall migration - ≤ 10 mg/dm² using EN 1186 Parts 3 and 9
    • Formaldehyde (specific migration) - ≤ 15 mg/kg using method in Article 8.5
    • Melamine (specific migration) - ≤ 2.5 mg/kg using method in Article 8.6
    • Nine heavy metals (specific migration) using method in Article 8.4:
      1. Aluminum - ≤ 1 mg/kg
      2. Barium - ≤ 1 mg/kg
      3. Cobalt - ≤ 0.05 mg/kg
      4. Copper - ≤ 5 mg/kg
      5. Iron - ≤ 48 mg/kg
      6. Lithium - ≤ 0.6 mg/kg
      7. Manganese - ≤ 0.6 mg/kg
      8. Nickel - ≤ 0.02 mg/kg
      9. Zinc - ≤ 5 mg/kg
  • Providing procedures and applicable analytical techniques for test parameters in the physical requirements and overall and specific migration requirements
  • Requirements for marking and labeling, including the use of the food contact safe symbol (a plate with a fork and spoon symbol, Appendix B) for compliant products
  • Sampling criteria (Appendix A)

The simulant for all migration tests is 3% Acetic acid.

Stakeholders should note the specific migration limits for the nine heavy metals match those for in the European Union – Regulation (EU) 2017/752, amending Regulation (EU) 10/2011 on ‘Food Contact Plastics’.



The draft document was prepared by the Thai Industrial Standards Institute (TISI) and circulated by the WTO in February 2019. Stakeholders have until April 14, 2019 to comment on the proposal.

SGS Food Contact Material Services

SGS’s technical experts are highly experienced in the testing of materials and articles that will come into contact with food. Utilizing SGS’s global network of testing laboratories, they will ensure products meet the appropriate regulations for food contact materials and pave the way for compliance. They offer the full range of testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Learn more about SGS’s Food Contact Material Services.

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