Food Contact Materials Regulation

Disclaimer: This document serves informational purposes only, does not constitute legal advice, and is no substitute for advice from legal counsel. It remains your sole responsibility to comply with the FCM and any contractual obligations towards Amazon. Any mention of FCM provisions in this document are for ease of reference only. Amazon does not provide any warranties about the completeness and correctness of these provisions or any other information provided in this document, and assumes no responsibility for any use of or reliance on this document.

UAE cabinet decision no. 20/2015 describes the standards that FCM needs to comply with to be sold in UAE market. UAE.S/GSO 2231 (the “FCM Regulation”) sets out general requirements that all Food Contact Materials need to comply with. Key GCC Standardization Organization (GSO) standards for Food Contact Materials in the United Arab Emirates (UAE) are:

• GSO 2231/2012 (General requirements for materials intended to come into contact with food)
• GSO 839/1997 (Food packages – Part 1: General requirements)
• GSO 1863/2013 (Food packages – Part 2: Plastic packages – General requirements)

If you sell Food Contact Materials, they must comply with the requirements of the FCM Regulation, and you shall comply with the minimum information requirements to consumers.

To which Food Contact Materials is the FCM Regulation applicable?

The FCM Regulation applies to materials and articles, including active and intelligent Food Contact Materials, which:

• are intended to be brought into contact with food
• are already in contact with food and were intended for that purpose
• can reasonably be expected to be brought into contact with food or to transfer their constituents to food under normal or foreseeable conditions of use.

This standard does not apply to:

• materials and articles which are supplied as antiques
• covering or coating materials, such as the materials covering cheese rinds, prepared meat products or fruits, which form part of the food and might be consumed with this food
• fixed public or private water supply equipment.

This Standard also establishes definitions, general requirements, labeling, and traceability.

What are the key obligations under the FCM Regulation?

Composition:

Food Contact Materials and articles must be manufactured in accordance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer or release their constituents into food at levels harmful to human health or change food composition, taste, or odor in an unacceptable way.

Food Contact Materials and articles should also comply with any applicable specific measures that concern:

• lists of substances authorised for use in the manufacturing of materials and articles; lists of authorised substances incorporated in active or intelligent Food Contact Materials and articles
• lists of active or intelligent materials and articles
• when necessary, special conditions of use for these substances and/or the materials and articles in which they are incorporated.

There are UAE specific measures on materials contained in Annex I of the FCM Regulation, including:

• Specification UAE.S GSO ISO 1863 on plastic materials
• Regulation UAE.S GSO ISO 6486-2 for ceramics

Labelling:

Materials and articles, which are not yet in contact with food when offered for supply or sale, should be accompanied by the following information:

• The words "for food contact" or a specific indication as to their use (such as wine bottle), or the symbol contained in Annex II of the FCM Regulation , unless it is clearly intended due to its characteristic for it to come into contact with food.

Documentation:

Emirates Conformity Assessment Scheme (ECAS) Certificate of Conformity or Emirates Quality Mark (EQM) Certificate of Conformity must accompany Food Contact Materials.

Any other obligations?

Producers and distributors have:

• a general obligation of due care in respect of safety requirements
• an obligation to inform market surveillance authorities if they know or ought to know, on the basis of information in their possession, that a Food Contact Material product poses a risk to consumers because it does not comply with the general safety requirement
• an obligation to cooperate with market surveillance authorities at their request to avoid risks posed by products that they supply or have supplied.

Additional Information

• More information about the GCC Standardization Organization (GSO) standards on Food Contact Material (FCM)
• More information on the European Food Contact Material Regulation