Thailand Overhauls Food Contact Material Regulations
On February 12, 2026, the Thai Food and Drug Administration (FDA) published a draft framework that restructures regulations by material type, allowing for more flexible future updates. The proposal includes transition periods ranging from two to five years, depending on the substance and industry readiness.
Key Changes by Material
Ceramics
Controls for ceramic food contact materials are maintained but updated with revised definitions, product categories, and safety provisions. Compliance with Thai Industrial Standards (TIS 601, 602, and 564) would be required, aligning with ISO 6486 and ASEAN limits for lead and cadmium migration. A two-year transition period is proposed.
Metals
A comprehensive new section for metal food contact materials covers tinplate, chromium-coated steel, aluminum, aluminum foil, and lacquered cans. The proposal establishes specific release limits for metal ions including aluminum, nickel, chromium, cadmium, lead, mercury, and arsenic. It introduces strict controls for epoxy-based can coatings:
- Bisphenol A (BPA) would be non-detectable
- Bisphenol A diglycidyl ether (BADGE) subject to specific migration limits
- Bisphenol F diglycidyl ether (BFDGE) and novolac glycidyl ether (NOGE) prohibited
New concentration limits for PFAS—both targeted and total—are proposed, following guidelines similar to the EU Packaging and Packaging Waste Regulation. Transition periods of three to five years are expected.
Glass
Glass food contact materials would be newly regulated, distinguishing between flat and hollow glassware. Migration limits for lead and cadmium align with TIS 603 and Japan's Notification No. 370. A two-year transition period is proposed.
Paper and Board
Paper-based materials—including coated, laminated, baking, cooking, and hot-filter papers—would be formally regulated for the first time. Compliance with TIS 2948 and 3438 is required, aligned with Germany's BfR recommendations and Council of Europe guidance. Chemical safety controls cover migration limits, optical brighteners, dyes, antimicrobial agents, and sensory neutrality. BPA would be non-detectable, BFDGE and NOGE banned, BADGE subject to migration limits, and PFAS regulated with concentration caps.
Enamelware
Enamel-coated metalware is removed from the scope, as it is no longer commonly used for commercial food packaging in Thailand.
Key Features of the New Framework
Throughout the proposal, numerical migration limits are not directly outlined in the notification but instead referenced via Thai Industrial Standards Institute (TISI) standards. This approach allows future updates without requiring new regulatory action.
General requirements across all materials explicitly prohibit reuse of containers previously holding hazardous substances and require food-grade colorants and printing inks.
Next Steps
The proposal represents a shift toward a migration-based, internationally harmonized regulatory model, strengthening controls on heavy metals, bisphenols, epoxy derivatives, and PFAS across multiple material types, and expanding oversight to materials not previously addressed. The proposal is open for public comment until March 31, 2026.
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