Thailand is streamlining its decades-old food contact materials regulation, proposing a material-specific regulatory structure aligned with standards developed by the Thai Industrial Standards Institute (TISI) and other international organizations.
On February 12, 2026, the Thai Food and Drug Administration (FDA) published a draft detailing expanded coverage beyond ceramics and enamelware to include metals, glass, and paper-based materials, while introducing clearer migration-based safety requirements and new controls for substances of concern such as bisphenols, epoxy derivatives, and per- and polyfluoroalkyl substances (PFAS).
Separate notifications would be issued by material type to allow more flexible future updates, and transition periods of two to five years depending on the substance and general testing readiness. This is part of a larger push by the Thai government in recent years to increase protections of food contact materials (FPF reported).
Throughout the proposed regulation, numerical limits for migration testing is rarely outlined directly in the notification but instead referenced via TISI standard to facilitate future updates without regulatory action.
Ceramics
The revised proposal maintains controls for ceramic food contact materials, but updates definitions, product categories (flatware, hollowware, infant food containers, and cookware), 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 (Pb, CAS 7439-92-1) and cadmium (Cd, CAS 7440-43-9) migration. General requirements explicitly prohibit reuse of containers previously holding hazardous substances and require food-grade colorants and printing inks. A two-year transition period is proposed.
Metals
The draft introduces a comprehensive new section for metal food contact materials, covering tinplate, chromium-coated steel, aluminum, aluminum foil, and lacquered cans. In addition to general hygiene and corrosion requirements, the proposal establishes specific release limits (SRLs) for a broad range of metal ions, including aluminum, nickel, chromium, cadmium, lead, mercury, and arsenic, drawing on Council of Europe guidance (FPF reported). It also introduces strict controls for epoxy-based can coatings: bisphenol A (BPA, CAS 80-05-7) would be non-detectable, bisphenol A diglycidel ether (BADGE, CAS 1675-54-3) would be subject to specific migration limits, and bisphenol F diglycidyl ether (BFDGE, 2095-03-6) and novolac glycidyl ether (NOGE) would be prohibited. New concentration limits for PFAS—both targeted and total, including polymeric PFAS—are proposed following the guideline outlined by the EU Packaging and Packaging Waste Regulation (PPWR, FPF reported). Depending on the substance, transition periods of three to five years are expected.
Glass
Glass food contact materials would be newly regulated under a dedicated section. The draft distinguishes between flat and hollow glassware and aligns migration limits for lead and cadmium with TIS 603 and Japan’s Notification No. 370. An additional parameter for alkalinity (expressed as sodium oxide) would also be introduced. As with other materials, requirements for food-grade colorants, printing inks, and prohibition of prior hazardous use are included. A two-year transition period is proposed.
Paper and board
Paper-based food contact materials, including coated, laminated, baking, cooking, and hot-filter papers, would be formally incorporated into the framework for the first time. Compliance with TIS 2948 and 3438—aligned with Germany’s Federal Institute for Risk Assessment (BfR) XXXVI recommendations and Council of Europe guidance—would be required. Beyond general hygiene provisions, the draft introduces chemical safety controls covering migration limits, optical brighteners, dyes, antimicrobial agents, and sensory neutrality. As with the metals, BPA would be non-detectable, BFDGE and NOGE would be banned, BADGE would be subject to migration limits, and PFAS would be regulated with substance-specific and total concentration caps. Where plastic coatings are present, compliance with Thailand’s plastic food contact regulation would also be required.
Enamelware
Enamel-coated metalware, previously covered, would be removed from the scope on the grounds that it is no longer commonly used for commercial food packaging in Thailand.
Consultation
Overall, the proposal is a shift toward a migration-based, internationally harmonized regulatory model, strengthening controls on heavy metals, bisphenols, epoxy derivatives, and PFAS across multiple material types, expanding regulatory oversight to materials not previously addressed, and streamlining language to allow easier updates in the future.
The proposal is open for comment until March 31, 2026.
See the Food Packaging Forum consultations page for more opportunities to comment on food contact regulations around the world.
References
Thai Food and Drug Administration. (February 11, 2026). “Request for opinions on the guidelines for improving the Ministry of Public Health Announcement No. 92 (1985) on determining the quality or standards of containers, the use of containers and prohibiting the use of any objects as food containers.” (in Thai).
Thai Food and Drug Administration. (February 11, 2026). “Clarifications and guidelines for improving the Announcement of the Ministry of Public Health No. 92 (1985).” (in Thai).
Read more
Sundae Ji. (February 12, 2026). “Thailand FDA Proposes Revision to FCM Regulation MOPH Notification No. 92 (B.E. 2528).” ChemLinked
Kerry Hebden. (February 18, 2026). “Thailand proposes major revisions to non-plastic food contact container rules.” Chemical Watch News and Insight
