Thailand’s Food and Drug Administration is consulting on amendments to Ministry of Public Health Notification No. 435 B.E. 2565 concerning plastic food-contact containers. The consultation opened on 16 September and is scheduled to close on 31 December 2026.

The proposal concerns permitted plastic materials, chemical migration requirements, recycled plastics and substances of concern used in plastic food-contact applications. It is relevant to polymer producers, compounders, packaging manufacturers, food businesses, importers and testing laboratories.

Proposed Material Changes

The consultation considers additional materials such as ethylene vinyl alcohol, polylactic acid, polybutylene succinate and polybutylene succinate adipate. Conditions for using recycled high-density polyethylene in food-contact applications are also addressed.

Manufacturers may need to demonstrate material identity, feedstock quality and compliance with applicable migration limits. Requirements affecting recycled plastics could create additional supplier-documentation and testing obligations.

BPA, PFAS and Additive Controls

Further proposals concern bisphenol A, polycarbonate materials, epoxy derivatives, phthalates and per- and polyfluoroalkyl substances. Depending on the final approach, manufacturers may need to reformulate products, substitute additives or provide additional analytical evidence.

The consultation reportedly presents alternative regulatory options for certain bisphenol A and polycarbonate controls. Companies should not treat one option as the final requirement before the amendment is adopted.

Industry Impact

Businesses should compare existing materials, additives, coatings and recycled feedstocks with the consultation documents. Technical comments supported by migration data, exposure assessments or information on suitable alternatives should be submitted before 31 December.

Existing requirements remain applicable while the proposal is under consultation.