Food Contact Material Regulations – Mercosur Region
In the Mercosur region the framework resolution for food contact materials (FCM) and articles (FCA) closely resembles those from the European Union (EU) and to certain provisions from the US FDA.
Mercosur (Mercado Común del Sur), the Common Market of the South, is the largest trading bloc in South America, comprising Argentina, Brazil, Paraguay, Uruguay and Venezuela. Its associate countries include Bolivia, Chile, Colombia, Ecuador, Guyana, Peru and Suriname.
The general safety of all FCM and FCA is governed by GMC Resolution Number 3/92, which requires these products to conform to requirements such as general safety and established limits for overall and specific migrations. (GMC Resolutions are approved by the Groupo Mercado Común, the Common Market Group, and must be transposed into national legislation.)
GMC Resolution 32/07 & 02/12
Food contact plastics are governed by GMC Resolution Numbers 32/07 (positive list of additives), 02/12 (positive list of monomers and polymers), 56/92 (general provisions and overall migration limits), and 32/10 (framework test conditions). The first two Resolutions are largely based on Regulation (EU) No. 10/2011 and former Directive 2002/72/EC from the European Union (EU), and to a lesser extent, the US FDA on food additives.
GMC Resolution No. 32/07 specifies the positive list of additives that may be used in the manufacture of food contact plastics, and GMC Resolution No. 02/12 specifies the list of monomers, polymers and other starting substances that may be used in the manufacture of food contact plastics and their restrictions. The use of simulants, including substitutes for olive oil, and testing conditions for temperature and duration is similar to those from former European Directive 82/711/EEC.
GMC Resolutions For Some Common Food Contact Materials and Articles
| GMC Resolution No. | Food contact material and article/remark |
|---|---|
| 3/92 | Overall framework |
| 55/92 | Glass and ceramics |
| 54/97 | Elastomers |
| 27/99 | Adhesives |
| 55/99 | Polymeric and resinous coatings |
| 46/06 | Metals and alloys |
| 32/07 | Positive list of additives for plastics |
| 15/10 | Colourants and pigments in plastics |
| 02/12 | Positive list of monomers and polymers for plastics |
| 40/15 41/15 42/15 |
Cellulose Cellulosic materials for cooking and hot filtration Cellulosic materials for cooking or ovens |
Specific Measures Affecting Bisphenol A (BPA)
Mercosur regulates the migration of BPA in food contact plastics and epoxy coating materials.
BPA is also prohibited in certain food contact plastics intended for young children in some Central and South American countries.
| Jurisdiction | Citation | Scope of BPA restriction | Requirement |
|---|---|---|---|
| Argentina | Disposición 2269/2012 | Polycarbonate baby bottles | Prohibited |
| Brazil | Resolution No. 41 of September 16, 2011 | Baby bottles | Prohibited |
| Costa Rica | Decree 35904-S, Gazette 76, April 2010 | Food contact materials and articles manufactured from polycarbonates for children | Prohibited |
| Ecuador | Resolution 29 of October 31, 2011 | Polycarbonate bottles for children up to 18 months | Prohibited |
Food Contact Testing
SGS has the expertise to help manufacturers and suppliers of FCM achieve compliance with markets around the globe. Our technical experts have extensive experience of testing materials and articles for many markets. We offer the full range of FCM testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Our experience can ensure your products meet the appropriate territorial regulations for food contact materials and help pave the way for compliance.