Indonesia Updates Food Contact Material Regulation with New Requirements for Food Packaging Safety
Under the new regulation, existing food packaging products must comply with the updated requirements within 12 months from the effective date. Certain migration requirements may be implemented gradually based on risk assessment results.
The regulation applies to a broad range of food packaging materials, including:
- Plastics
- Rubber and elastomers
- Paper and paperboard
- Ceramics
- Glass
- Metals and metal alloys
- Multilayer packaging materials
The updated framework introduces requirements covering migration testing, authorized food contact substances, restricted substances, and specific provisions for recycled and reusable food packaging.
Migration Requirements for Food Contact Materials
Migration testing serves as a key component of Indonesia's updated food packaging safety framework.
Food contact materials must comply with both overall migration limits and specific migration limits. Overall migration limits evaluate the total amount of substances that may migrate from packaging materials into food, while specific migration limits control individual substances with potential health risks.
For plastic food packaging materials, the regulation establishes an overall migration limit of:
- 60 mg/kg of food, or
- 10 mg/dm² of food-contact surface area
The regulation also specifies migration limits for various substances associated with different polymers, including certain monomers, additives, and residual substances.
Positive and Negative Lists for Food Contact Substances
The regulation establishes a positive list containing more than 1,300 authorized food contact substances, including additives, stabilizers, antioxidants, colorants, adhesives, coating components, lubricants, and other materials used in food packaging applications.
Certain substances of concern remain permitted under controlled conditions with specified migration limits.
For example, bisphenol A (BPA) and bisphenol S (BPS) are included in the authorized substance list for certain applications, subject to a migration limit of 0.05 mg/kg of food. BPA is prohibited in polycarbonate food-contact articles intended for infants and children under three years old.
The regulation also establishes a prohibited substances list covering certain chlorinated solvents, carcinogenic substances, asbestos, chromates, and specific fluorinated compounds.
Requirements for Reusable and Recycled Food Packaging
The new regulation introduces dedicated provisions for reusable and recycled food packaging materials.
Reusable packaging must continue to meet applicable migration requirements throughout its intended service life. Recycled food packaging materials are generally required to comply with the same safety requirements applicable to virgin food contact materials.
These provisions establish regulatory requirements for the use of recycled materials in food packaging applications while maintaining food safety standards.
Approval Process for New Food Contact Materials
The regulation provides a formal approval pathway for new food contact substances and packaging materials not currently covered.
Companies seeking approval must submit relevant documentation to BPOM, including:
- Applicant information;
- Details of the food contact substance or material;
- Testing data and safety assessment results.
New substances or materials may only be used after receiving written approval from BPOM following a safety evaluation.
Industry Implications
Indonesia's updated food packaging regulation represents a further development of the country's food contact material management system.
For packaging producers, raw material suppliers, and related industries, compliance with migration requirements, authorized substance lists, and documentation standards will become increasingly important.
Market participants are advised to review the updated regulatory requirements and evaluate their products' compliance status during the transition period.