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Thailand has proposed a draft regulation to regulate cleaning and sanitizing products used for food as “controlled food,” categorizing them as “food additives.” The Notification, Draft MOPH Notification (No…) B.E… (…), issued by virtue of the Food Act B.E. 2522, entitled "Cleaning or sanitizing products for food production and products," was notified to the WTO’s Committee on Sanitary and Phytosanitary Measure (SPS) on 11 December 2018.
Aiming for better consumer protection, the Draft regulation proposes new regulatory measures to control the use of chemicals in food production or those that come directly in contact with food products such as produce and meat product washes.
The comment period for this Notification ends on 9 February 2019. The Regulation is proposed to be enforced six months from publication.
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The proposed regulation seeks to regulate cleaning and sanitizing products used for food as “controlled food” and defines them as “food additives.” Under this Notification, “cleaning and sanitizing products” are defined as food additives purposely used as aiding substances in rinsing, cleaning, eliminating or decreasing potentially harmful substances by physical, biological or chemical processes, as the case may be. They are further sub-divided into three categories: 1) cleaning products; 2) sanitizing products; and 3) cleaning and sanitizing products. All of these products must comply with the qualities and standards prescribed in the regulations.
Cleaning and sanitizing products used for food or active ingredients in products must not be harmful or cause health hazards, and must conform to the conditions under one of the following internationally recognized standards:
- Codex Advisory Specification for the Identity and Purity of Food Additives
- Food Chemicals Codex Monograph (FCC Monograph)
- US Code of Federal Regulations Title 21
- Approved by the Thai FDA in accordance with the MOPH Notification Re: “Food Additives”
Composition of Product
Other ingredients used in the products described in the regulations and contaminants must be safe for consumption and conform to prescribed conditions as well as other concerned regulations. This includes Thailand’s requirements for the use of food additives and flavoring agents.
The use of key and active ingredients must comply with the permitted list as shown in the annex. This includes types of products, technological functions, types of foods, maximum levels permitted (mg/kg), maximum residues levels (MRL) mg/liter and other conditions specified in the annex of the regulation. Manufacturers or importers shall submit the document for a safety assessment as specified in the Notification of the Ministry of Public Health (No. 281) B.E. 2547 (2004) Re: Food Additives dated 18 August 2004.
When the products contain other ingredients, it is required that the contaminant level not be more than 3 mg/kg for arsenic and 10 mg/kg for lead.
Products in this draft notification shall comply with the Notification of the Ministry of Public Health Re: Food Additives. Labels shall display the required information such as the name of the food, instructions for use (including product preparation and direction for removal from food), precautionary statements, first aid measures and other statements as required by the Thai FDA.
Products that contain surfactant agents used for cleaning produce must follow specific requirements as prescribed in the regulation.
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Food importers and manufacturers will need to evaluate the draft regulation and submit comments as necessary. Member countries of the WTO have until 9 February 2019 to submit comments.
The National Bureau of Agricultural Commodity and Food Standards (ACFS) under the Ministry of Agriculture and Cooperatives is responsible for issuing this regulation. Comments or suggestion can be sent to the address below or to the ACFS website.
National Bureau of Agricultural Commodity and Food Standards (ACFS)
50 Phaholyothin Road, Ladyao Chatuchak,
Bangkok 10900 Thailand
Tel: +(662) 561 4024 Fax: +(662) 561 4034