Overview of Packaging Legislation in Pakistan

1.3 General requirements

I. Food Packaging/contact materials are all materials and articles intended to come into contact with food, such as packaging and containers, kitchen equipment, cutlery, and dishes. These can be made from a variety of materials including plastics, rubber, paper, and metal. Food contact materials also include those used in processing equipment, such as coffee makers or production machinery as well as containers used in transport action. The safety of materials in contact with food must be evaluated as molecules can migrate from the materials into the food. The materials and articles, including active and intelligent materials and articles, shall be manufactured in compliance with good manufacturing practices so that, under normal or foreseeable conditions of usage, they do not transfer their constituents to food in quantities that could:

1. endanger human health; or
2. bring about an unacceptable change in the composition of the food; or
3. bring about a deterioration in the organoleptic characteristics thereof.

Food contact materials and articles comprise a broad and complex range of goods. Among the most widely used materials are the plastic packaging materials and articles used for bottles, utensils, films, and containers which are intended to be placed in contact with food. Plastic packaging materials include many types such as flexible films, soft, semi-rigid, and rigid materials. Many modern forms of plastic packaging make use of many of these in a single packaging product and they will also contain adhesives to bond layers together and coatings that allow the packaging to protect the food under what are often physically difficult conditions during controlled processing and transportation. Increasingly, many plastic packaging materials can be wholly or partly made from recycled material. The following general requirements for plastic packages used in packaging food materials shall be met:

1. All plastic raw materials used in manufacturing food packages shall be of known origin and composition to avoid the use of scrap or used raw materials. In-house recycling is exempted. 
2. They shall be clean and homogeneous, free from any foreign material, swelling, or air pockets. 
3. They shall not cause any hazard to consumer health.
4. They shall not lead to the degradation of sensory properties of the packaged food material or the occurrence of undesirable changes in the nature and quality of food material.
5. Pigments, coloring materials, and other components used in their formulation and manufacture shall be nonpoisonous and with no tendency for migration which may cause migrated components to react or mix with the food material.
6. They shall be resistant to impact effects caused by shocks and mechanical vibrations.
7. They shall not be affected by heat during filling, closing, storing, transportation, or handling, in a way that deforms them or changes their composition, chemical or physical properties; or increases probabilities of reactions and migrations of monomers or additive materials within the permissible level.
8. Their resistance to acids and bases shall be suitable to the packaged food material, for intended life.
9. The pH of a water solution within the range of 6-8 shall not be changed when placed in the package for one hour.
10. They shall be non-reacting with organic solvents and oils in packaged food materials if stored for over 10 days. 
11. Their permeability to water vapor shall be suitable for the packaged food material for its intended life.
12. Their permeability to gases shall be suitable for the packaged food material for the intended life of the product. 
13. They shall not be affected by light when exposed to it, till the intended life of the product. 
14. They shall have the ability to attain tight closure (or sealing) when hermetic sealing is used for food materials if intended by the product.
15. The concentration (content) of vinyl chloride monomer shall not exceed 1 mg per kg of the plastic material in the final product.
16. Bisphenol-A is not permitted to be used for the manufacture of polycarbonate infant feeding bottles.
17. In the case of manufacturing multilayered packages from more than one material, it shall be necessary to get rid of the remaining solvents, gluing materials, or major materials, such that the remains of all those solvents together shall not exceed 5 mg per square meter of the package surface.
18. The solvents used in printing must be organic compounds consisting of alcohols, hydrocarbons, glycol ethers, and esters. The usage of toluene, ethyl acetate, and hexane is banned. 

1.4 Labeling requirement of food packaging/contact materials

The business operator will be responsible for ensuring the following labeling requirements during the manufacturing or processing of food packaging/contact materials:

I. Materials and articles, which are not yet in contact with food when placed on the market shall be accompanied by the words “for food contact” or the fork and glass symbol.

Figure 1: Fork and glass symbol

II. If necessary, special instructions to be observed for safe and appropriate use;

III. The name or trade name and the contact details of the manufacturer, processor, or seller responsible for placing on the market;

IV. Adequate labeling or identification to ensure traceability;

V. In the case of active material and articles, information on the permitted use(s) and name and quantity of the substances released by the active component.

The information required above shall be clearly legible and indelible. The retail trade of materials and articles shall be prohibited if the information provided to the purchasers is not given in a language easily understood by them:

1. At the marketing stages other than the retail stage, the information required above shall be displayed on:
   1. The accompanying documents “declaration of compliance” or
   2. The labels or the packaging, or
   3. The materials and articles themselves;
2. At the retail stage, the information required above shall be displayed on:
   1. The materials or articles or on their packaging, or
   2. Labels affixed to them or
   3. A notice in the immediate vicinity of the materials or articles

Additional rules on labeling shall be considered for the active and intelligent materials and articles including the released active substances to allow identification by the consumer of non-edible parts, active and intelligent materials and articles or parts thereof should be labeled with the appropriate words “DO NOT EAT” or accompanied, where technically possible, by a symbol, (Figure. 2) whenever materials and articles or parts of them are perceived as edible.

NOTE: Manufacturers must print the type of plastic material on the packaging preferably on the bottom of the package (either name or abbreviation).

VI. The traceability of any food contact material and article including plastic, active, and intelligent materials and articles shall be ensured at all stages in order to facilitate control, the recall of defective products, consumer information, and the attribution of responsibility.

With due regard to technological feasibility, business operators shall have in place systems and procedures to allow identification of the businesses from whom and to whom materials or articles and where appropriate, substances or products are supplied. The food packaging/contact materials and articles that are placed on the market shall be identifiable by an appropriate system that allows their traceability by means of labeling or relevant documentation or information.

1.5 Compositional requirements of food packaging/contact material

I. Plastics are made by condensation polymerization (poly-condensation) or addition polymerization (poly-addition) of monomer units. In poly-condensation, the polymer chain grows by condensation reactions between molecules and is accompanied by the formation of low molecular weight byproducts such as water and methanol.

II. Plastics as well as ion exchange resins, rubbers, and silicones are macromolecular substances obtained by polymerization processes. As those materials are composed of different substances than plastics and have different physico-chemical properties specific rules for compositional requirements need to apply and it shall be made clear that they are not within this section of this code.
III. There are several types of plastic that are used in food packaging and can be identified by its Plastic Identification code (PIC) - usually a number or a letter abbreviation presented at the bottom of plastic packaging.

IV. Multiple types of plastics are being used as materials for packaging food, including polyolefin, polyester, polyvinyl chloride, polyvinylidene chloride, polystyrene, polyamide, and ethylene vinyl alcohol. Although more than 30 types of plastics have been used as packaging materials, polyolefins, and polyesters are the most common.

V. The recycling symbols will be affixed on the front side of the disposable plastic packaging and single-use containers. Non-disposable food-use goods like dinnerware, pitchers, flatware, and baby bottles shall not have a recycling label.

In addition, The Punjab Food Authority recognizes the lists of substances authorized for use in the manufacturing of plastics based on International Bodies and other countries (e.g. EU, USA, FSANZ, Japan) lists. The EU list of authorized substances is being used and stated in Annex 1 of the Punjab Regulation [1].

1.6 Migration limits of food contact material

Specific and overall migration limits are laid down in the Punjab Regulation (Sections 10, 11, and Annex 1) [1]. Food Packaging/Contact Material shall not transfer their constituents to foods in quantities exceeding the specific migration limits (SML) mentioned in Annex 1. These SML are expressed in mg of substance per kg of food (mg/kg). For substances for which no specific migration limit or other restrictions are provided in Annex 1, a generic specific migration limit of 60mg/kg shall apply.

Food Packaging/Contact Material intended to be brought into contact with food excluding those for infants and young children shall not transfer their constituents to food simulants in quantities exceeding 10 milligrams of total constituents released per dm² of food contact surface (mg/dm²).

1.7 Declaration of Compliance

At the marketing stage other than the point of sale to the final consumer, Food packaging/Food contact material shall be accompanied by a written declaration stating that they comply with the rules applicable to them. Appropriate documentation shall be available to demonstrate such compliance. Such a declaration of compliance is required and is done during a food product registration.

2. Expected regulatory changes, if any

Two major international beverage manufacturers have approached authorities seeking permission to use recycled PET bottles for their carbonated beverages. Although there is no legislation yet allowing recycled PET usage for food packaging, authorities have allowed these beverage industries based on the analysis/testing reports evidencing non-leaching of the plastics in the beverages. It is expected that the use of recycled plastics for food packaging material will be addressed from a more formal regulatory standpoint in the near future.