Page 70 - FoodFocusThailand No.216 MARCH 2024

STRONG QC & QA

polyethylene terephthalate (PET) can be used in this specific substances used in the manufacturing process, but
reprocessing. If the plastic container is made from recycled verifiable evidence guaranteeing the use of said chemicals in
plastic beads approved by the Thai Industrial Standard (TIS), it the production process is required. Manufacturers can select
can also be used without submitting a safety assessment result. testing conditions and food simulants that best suit the real
• Type 3 – Tertiary recycling and chemical reprocessing: environmental conditions of usage, similar to those specified
used plastic containers for food are converted back into their in the overall migration limits testing in Point 2. If the food
original materials via chemical reprocessing. According to the container is made from plastic whose reactants used in the
notification, this reprocessing only applies to 13 plastic types. manufacturing are one of the 4 types of PPAs, which are
mentioned in the Table (3) of the notification of the Ministry of
Standards of Food Packaging Made from Plastic Public Health, said container must be tested for PPAs migration
according to the Notification of the Ministry of and must show verifiable evidence reflecting the use of said
Public Health (No.435) B.E.2565 (2022) substance in their production processes. If other types of PPAs
Specifications and test requirements stipulated in the new that are not included in the aforementioned reference are used,
notification differ from those in the previous version in many the overall limit of detection must not exceed 0.01 mg/kg.
aspects. They are based on the Commission Regulation (EU) 4. Specific migration limits: testing will be performed
No. 10/2011 and its amendments. Safety and quality evaluation depending on the type of plastic in food containers, as shown
of food packaging made from plastic includes the following in Table 3.
aspects: 5. Plastic containers must not contain microbial
1. Overall migration limits: suitable food simulants can pathogens: the Food and Drug Administration has prescribed
be chosen to match their respective food types as shown in a detection guideline for 4 types of pathogenic microorganisms
Table 1. in food packaging: Salmonella spp., Staphylococcus aureus,
Overall migration limits testing in each food simulant must Bacillus cereus, and Clostridium perfringens
not yield results that exceed 10 mg/dm . If the food packaging The Food and Drugs Administration has relaxed certain
2
is compatible with any food type, or if the food type to be used points of the enforced regulations as per the details below so
with the packaging is unspecified, the use of ethanol 10% (v/v), that food operators and certifying bodies can make corresponding
acetic acid 3% (w/v), and vegetable oil is recommended. Testing preparations to ensure proper quality assessment after the
conditions depend on the functional use of the packaging as enforcement of the notification of the Ministry of Public Health
follows: No.435:
1.1 Test at 40 C for 10 days applies to food containers • Usage of containers produced and sold before the
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intended for food storage (A) at low or room temperatures for enforcement of this notification is allowed until June 18, 2025,
no longer than 30 minutes, (B) in chilling or freezing conditions, but the containers are required to undergo corresponding quality
and (C) at room temperatures for a brief or extended period as inspection as prescribed by Annex 2, attached at the end of the
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well as for hot filling or heating at 70-100 C, including frozen notification.
food defrosting or microwave food heating at temperatures no • Quality inspection of containers produced and sold after
higher than 100 C for no longer than 15 minutes. the enforcement of this notification is allowed to follow the
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1.2 Test at 100 C or reflux extraction for 2 hours is suitable conditions prescribed by Annex 2 attached at the end of the
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for food containers used with temperatures higher than 100 C notification until June 18, 2025.
and for thermal disinfection with temperatures up to 121 C. • Usage of recycled polyethylene terephthalate (rPET) shall
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Such conditions are suitable for containers made from polyolefin immediately adhere to the regulations prescribed by the
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and microwave cooking at temperatures > 100 C or < 100 C notification, but the quality assessment of said material is
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more than 15 minutes. Testing at 100 C using a vegetable oil allowed to be carried out in accordance with Annex 2 attached
as food simulant and Reflux extraction is performed with a at the end of the notification until June 18, 2025.
simulant that requires water as a solvent.
1.3 Test at 175 C for 2 hours applies to containers of fat-
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based food using at temperatures higher than 121 C or non-
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polyolefin containers. If technical limitations prevent using More Information Service Info C009
vegetable oil in the test, it can be performed by using tenax and
vegetable oil at 100 C for 2 hours or 40 C for 10 days, depending
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on the intended storage time. เอกสารอ้างอิง / References
2. Migration limits of 19 metal types: the overall migration 1 AUTUMN STATEMENT 2023. [Online]. [Cited 2 February 2024].
limits for these metal types are shown in Table (2) of the Available from internet: https://assets.publishing.service.gov.uk/
notification of the Ministry of Public Health. During the test, a media/656890a95936bb00133167cd/E0298247 3_Autumn_Statement_
sample is extracted via acetic acid 3% (w/v) in a testing condition Nov_23_BOOK_Print_for_online_Final.pdf
that resembles the real environmental conditions of usage. If 2 Ragonnaud G., Revision of the Packaging and Packaging Waste
the real conditions are unknown, the test shall be conducted at Directive, BRIEFING EU Legislation in Progress, 2023, p.3-6.
60 C for 10 days. If the real conditions are known or specified, 3 ประกาศกระทรวงสาธารณสุข (ฉบัับัท่� 435) พ.ศ.2565 ออกตามความใน
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the test shall adhere to the following conditions as shown in พระราชบััญญัติอาหาร พ.ศ.2522 เร่�อง กำาหนดคุณภาพหร่อมาตรฐานของ
Table 2. ภาชนะบัรรจุุท่�ทำาจุากพลาสติก
3. Primary aromatic amines (PAAs): colored or printed ประกาศสำานักงานคณะกรรมการอาหารและยา เร่�อง การตรวจุวิเคราะห์
containers and packaging are required to test for PAAs migration. ภาชนะบัรรจุุท่�ทำาจุากพลาสติก
The prescribed 22 types of azocolourant must not exceed the [เข้าถึึงวันท่� 1 กุมภาพันธ์ 2567]. เข้าถึึงได้จุากเว็บัไซต์
limit of detection (LOD) or 0.002 mg/kg. Testing can be done on https://food.fda.moph.go.th/media.php?id=509721043905159168&na
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