Hygiene Standards for FCM

Hygiene Standards for FCM
Thailand

The below version control table serves to document all updates made to the report. The purpose is to ensure the information is always accurate and up-to-date.

1. Overview of relevant regulatory standards on hygiene standard for food contact materials

The general requirements for food packaging are specified by the Food Act B.E. 2522 [1], specifically Chapter 4, which outlines the requirements for food containers in the form of criteria for impure, adulterated, or substandard food: 

• Food containers must not be made of materials likely to pose health risks or contaminate the food. 
• Food is deemed impure if it is: 
  • Packed or stored in an unhygienic manner. 
  • Contained in materials that could be dangerous when used for food storage. 
• Containers must comply with prescribed quality and safety standards. Any deviation, even if not harmful, renders the food substandard. 
• Food is considered unsafe if the packaging compromises its safety, value, or usefulness. Inappropriate packaging is prohibited. 
• The FDA Secretary has the authority to:
  • Order modifications or repairs to production or storage facilities to maintain hygiene. 
  • Suspend the production or import of food in unsafe or inadequate containers. 
  • Publicize analysis results of food or packaging found to be impure, adulterated, or harmful, identifying the producer and distributor if known, class or description of the food or containers and if the food or containers have trade names or lot number, the trade name or lot number, as the case may be. 

2. General Standards for Hygiene Requirements for Food Contact Materials

Hygiene requirements for food production, including packaging hygiene, are outlined by the Thai Ministry of Public Health (MOPH) in the Notification on Good Manufacturing Practice (GMP) principles for Food Production Processes, Processing Equipment/Utensils, and Storage Practices (GMP 420) [2]. 

Accordingly, food containers, or food contact material (FCM), are an essential focus of control measures for food producers, designed to prevent contamination and eliminate biological, chemical, and physical hazards that could impact the food production process. FCM must comply with safety and suitability standards to prevent contamination and ensure food safety during production, storage, and distribution. 

Specific Requirements for FCM 

• Sourcing and Inspection 
  • Packaging materials must meet established safety, suitability, and cleanliness standards.
  • Inspections should verify the absence of defects and ensure the integrity of seams and other critical packaging components. 
• Storage and Transportation
  • Packaging must be stored and transported in conditions that prevent contamination or damage.
  • An effective stock management system must be implemented to ensure proper handling and inventory control. 
• Cleaning and Sanitization
  • Packaging may require washing or sanitization to remove dirt or contaminants. 
  • Cleaned or sanitized packaging must be handled in controlled environments to prevent re-contamination. 
  • Contingency measures should be in place to avoid cross-contamination in the event of delays in the filling process. 

Container Filling and Sealing

• Filling and Sealing
  • Containers must be promptly filled and sealed to prevent contamination. 
  • Measures must prevent re-contamination from equipment or workers. 
  • Food temperature must be controlled during filling. 
  • Seals or seams must be inspected for quality. 

Traceability and non-conformity

Processes must be documented. Maintain detailed records of raw materials, additives, packaging, and finished products to ensure traceability and enable root-cause analysis for non-conformities or contamination.

Non-conformity products shall be appropriately managed by separation or destruction in order to prevent distribution for sale or consumption. Records and reports shall be maintained for at least one year after the date shown on product labels. 

3. Specific Hygiene Requirements per Type of Food Contact Materials 

3.1 Liquor Bottles (B2C): Glass

No specific hygiene requirements are specified for liquor bottles; the general provisions for processed food outlined in Section 2 above apply. 

3.2 Casks and Barrels (B2B): Wood

No specific hygiene requirements are outlined for wooden casks and barrels; the general provisions for processed food in Section 2 above apply. 

Note: the import of any goods and commodities into Thailand which are covered by wood packaging material as packages or containers must be accompanied by a phytosanitary certificate, but this requirement excludes barrels for spirit or wine which have been heated during manufacture [3]. The certification requirement of wood used for external packaging (e.g. pallet) not in contact with food is outside the scope of this project. 

3.3 Casks and Barrels (B2B): Metal

No specific hygiene requirements are outlined for metal casks and barrels; the general provisions for processed food in Section 2 above apply. 

4. Summary Table

5. References

1. Food Act B.E. 2522 

https://exfood.fda.moph.go.th/law/data/act/E_FoodAct2522.pdf

2. Notification of the Ministry of Public Health (No. 420) of B.E. 2563 Re: Food Production Processes, Processing Equipment/ Utensils and Storage Practices 

https://food.fda.moph.go.th/media.php?id=509431569765769216&name=P420_E.pdf

3. Plant Quarantine Act B.E. 2507 Amended by Plant Quarantine Act (No. 2) B.E. 2542 and Plant Quarantine Act (No. 3) B.E. 2551

https://www.doa.go.th/ard/wp-content/uploads/2019/10/P.Q._Act_B.E._2507_amended_English_version_21.pdf