On August 27, 2026, the Food Packaging Forum (FPF) submitted comments, accessible here and here, on two draft standards prepared by the Bureau of Indian Standards (BIS): one covering plastic feeding and drinking containers, accessories and cutleries for child use, and another covering plastic containers for microwave use.
The draft standard for children’s food contact materials includes provisions addressing bisphenol A (BPA, CAS 80-05-7), polyvinyl chloride (PVC), di-ethylhexyl phthalate (DEHP, CAS 117-81-7), selected heavy metals, and other known hazardous substances such as 6PPD (CAS 793-24-8), N-Nitrosoamines and N-Nitrosatables. Among other measures, it proposes prohibitions on BPA, PVC, and 6PPD, as well as migration testing requirements and specific migration limits for selected substances.
The draft standard for microwave-use plastic containers establishes specific migration limits for selected heavy metals and DEHP. It also appears to permit the use of recycled or reprocessed polyethylene terephthalate (PET), polypropylene (PP), and polyethylene (PE) in microwave food contact applications, subject to standards set by the Food Safety and Standards Authority of India (FSSAI).
While welcoming these measures, FPF highlighted the need for the chemical safety provisions of both draft standards to be further strengthened to adequately protect public health based on the latest available scientific evidence.
For the draft standard on children’s products, FPF highlighted five areas for consideration:
- Expanding the list of chemicals beyond the limited list currently specified,
- Evaluating chemical groups rather than individual substances to avoid regrettable substitutions,
- Cumulative chemical exposures and mixture effects,
- Addressing non-intentionally added substances (NIAS), and
- Releases of microplastics and nanoplastics (MNPs) during repeated use
In its comments on the microwave container standard, FPF similarly highlighted the limited consideration of food contact chemicals beyond those currently regulated.
FPF additionally raised questions regarding provisions allowing the use of recycled PET, PP, and PE in microwave-use plastics. While the draft notes that this would be subject to FSSAI standards and guidelines, it is unclear which specific requirements would apply to recycled PP and PE, as FSSAI has published provisions only relating to recycled PET for food contact applications.
FPF further raised concerns related to the chemical safety of recycled plastics (FPF reported). Scientific studies have repeatedly demonstrated that recycled plastics can contain increased levels of contaminants originating from previous uses, mixed waste streams, degradation processes, or other unintentionally present substances (FPF reported and here). These considerations are particularly relevant for microwave food contact applications because elevated temperatures can increase chemical migration into food.
To support the continued development of the standards, FPF pointed BIS to its free and publicly available FCCmigex and FCCprio databases, which compile scientific information on food contact chemicals, chemical migration, and chemicals of concern.
References
Bureau of Indian Standards (2026). “PCD 21 (33814) – Plastic Feeding and Drinking Containers, Accessories and Cutleries for infant and child use – Specification.”
Bureau of Indian Standards (2026). “PCD 21 (33943) – Plastic Containers for Microwave use – Specification.”
Food Packaging Forum (July 30, 2026). “FPF Comments on Draft Indian Standard PCD 21 (33814) – Plastic Feeding and Drinking Containers, Accessories and Cutleries for infant and child use – Specification.” (pdf)
Food Packaging Forum (July 30, 2026). “FPF Comments on Draft Indian Standard PCD 21 (33943) – Plastic Containers for Microwave use – Specification.” (pdf)
