• Food Contact Material Regulations in Australia: An Overview

    Posted on 7 Comments

    Food Contact Material Regulations Australia

    Planning to import lunch boxes, drinkware, cutlery, or other food contact materials to Australia? In this guide, we introduce you to AS 2070:1999, AS 4371:2012, lab testing, labeling and other requirements when importing and selling food contact materials in Australia.

    Mentioned Products

    • Food packaging
    • Plastic containers
    • Plastic bottles and jars
    • Ceramic bowls
    • Ceramic knives
    • Ceramic cutting boards
    • Ceramic mugs

    AS 2070:1999 Requirements for Plastic Food Contact Materials

    AS 2070:1999 is an Australia standard that applies to food contact materials that are made of plastics materials, such as resins, granules, and powders. Applicable products include:

    • Plastic packages
    • Plastic food and beverage containers, lunch boxes, water bottles, and jars
    • Plastic wrapping materials
    • Plastic utensils

    Note that the standard refers to both US FDA 21 CFR and EU FCM regulations. It also states that new plastic material shall be in compliance with food contact polymers requirements in the US and EU.

    AS 4371:2012 Requirements for Ceramic Tableware

    AS 4371:2012 is an Australian standard that regulates ceramic tableware. The standard specifies the maximum permissible migration degree of heavy metals such as lead and cadmium from ceramic tableware. The following are examples of products for this kind:

    • Ceramic bowls
    • Ceramic knives
    • Ceramic cutting boards
    • Ceramic mugs

    Food Standards Code

    The Food Standards Australia New Zealand (FSANZ) is an agency established by the Food Standards Australia New Zealand Act 1991 (FSANZ Act). FSANZ developed standards for food and food contact materials in Australia and New Zealand.

    The agency established the Australia New Zealand Food Standards Code in 2000, which develops standards that regulate the use of ingredients, additives, and some edible chemicals in food and food contact materials, labeling requirements, and quality control system during food production and processing.

    For food contact materials, this code specifically regulates food, food packaging, and more.

    Food Packaging

    The Code sets out requirements for food packaging materials in Standard 1.1.1-10 (11). It requires that substances used in packaging materials in contact with food must not pose any harm, distress, or discomfort to the human body. Examples of restricted articles include

    • Moisture absorbers
    • Mold inhibitors
    • Oxygen absorbers
    • Promotional materials
    • Writing inks on the package

    In addition, the Code also specifies the acceptable maximum levels of heavy metals, non-metal substances, and natural toxicants contained in food in Standard 1.4.1. Restricted substances include

    • Lead
    • Tin
    • Acrylonitrile
    • Vinyl chloride
    • Erucic acid

    The Code also elaborates on the use of recycled and reused materials for food contact materials, given that such materials do not contaminate or change the nature of the food in an unacceptable way and also properly sanitized after recycling.

    Food Processing Aids

    The Code restricts the use of food processing aids, which are defined as substances that alter the composition or nature of the food for technical purposes. Only substances listed in Schedule 16, Section S16-2, and Section 18 of this code can be used during food processing and within the food and its packaging.

    Beneath are examples of permitted substances:

    • Antifoam agents
    • Ion exchange resins
    • Lubricants and release agents
    • Processing aids for water
    • Microbial control agents

    Lab Testing

    Testing Methods

    Food contact materials regulations typically involve migration testing, in order to assess the amount of transfer of substance from the product – or packaging – into the food or beverage.

    Here some standards and regulations relevant for FMC in Australia:

    • AS 2070:1999
    • AS 4371:2012
    • 21 CFR Parts 170:199 (US)
    • Directive 96/11/EC (EU)

    Testing Costs

    The cost to conduct a set of lab tests for food contact materials can range from a few hundred to several thousands of dollars, depending on the type of tests you choose. The price can also be affected by the material and quantity of the tested product.

    List of FCM Testing Companies

    • SAI Global
    • SGS
    • TÜV
    • Intertek

    State Regulations

    Western Australia: Health (Food Hygiene) Regulation

    Food contact materials, including food and beverage containers, household appliances that are made of glazed ceramic or glass should comply with the British Standard 6748:1986 in the territory of Western Australia. The standard sets limitations on the amount of metal migration to food.

    This standard was first referred to in the Health (Food Hygiene) Regulation 1993, which was repealed in 2009. However, British Standard 6748:1986 is still relevant to Western Australia.


    Does Australia accept FCM compliance with EU food contact materials standards?

    Although Australia doesn’t directly accept EU FCM regulations, Australian Standard AS 2070-1999 explicitly refers to several EU directives such as Commission Directive 96/11/EC relating to plastic materials and articles intended to come into contact with foodstuffs, and others.

    Does Australia accept FCM compliance with USA (FDA) food contact materials standards?

    Australian Standard AS 2070-1999 for plastic food contact materials explicitly refers to FDA’s regulations on the same subject, such as 21 CFR Parts 170:199, and requires the compliance of such products.

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    Disclaimer: The content on this website is provided for general information only. The content includes summaries written by our team members based on publicly available information about product safety standards, labeling, documentation, testing, processes, and other product compliance related topics. However, we don’t guarantee that we cover every single relevant regulation/standard/requirement, or that the information is free from errors, or covering every single scenario and exemption. We do make mistakes from time to time. We never provide legal advice of any sort.

    Changes/Updates: Product standards and substance restrictions are subject to frequent updates and changes. In addition, new regulations, standards, and/or requirements may also become effective at any time. We don’t update our articles whenever new standards/regulations/rules are added or changed. We recommend that you consult a lab testing company or other professional to get the latest information about mandatory standards/regulations in your market, country, or state. Lab testing companies generally stay up to date on new and updated standards and regulations.

    National/State-Level Standards/Regulations: Many articles don't cover all European national and US state standards, regulations, and requirements. We recommend that you consult a testing company or other professional to confirm all relevant (and current) national/state level standards and regulations.
  • 7 Responses to “Food Contact Material Regulations in Australia: An Overview

    1. Andy Good at 7:54 am

      How do i know that a CVT made of plasticised vinyl choride is ‘food grade’ as per AS2070. The compliance code is not printed on the tubing like others I have seen. Is there a difference between a makers label ‘food contact cvt’ and the AS2070? Thanks Andy

      1. Fredrik Gronkvist at 9:56 am

        1. What is a CVT?

        2. Can the seller provide a test report?

    2. Ash Oldershaw at 7:29 am

      Hi There,

      Trying to find a PDF copy of AS2070-1999. Can anyone oblige?

      1. Fredrik Gronkvist at 12:20 pm

        Hi Ash,

        You should be able to buy it from here: https://www.techstreet.com/standards/as-2070-1999?product_id=2048212

    3. Katherine Xiong at 9:25 am

      Hello, I would like to inquire about the certification required by USA for bamboo cup export.It may be an FDA registration and test report, or it may be a USDA related registration. Could you give me some help, please?

      1. Fredrik Gronkvist at 12:23 pm

        Hi Katherine,

        It could be both actually. One does not exclude the other.

        I suggest you read this article: https://www.compliancegate.com/united-states-wood-and-bamboo-product-regulations/

    4. Stanley Thomas at 3:03 pm

      Regulations, standards, certification, and testing requirements for kitchen products, lunch boxes, food packaging,and more.

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