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# FSANZ Food Contact Materials Compliance in Australia

Any plastic, metal, coating, adhesive, or ink that comes into contact with food in Australia is regulated under the Food Standards Code — administered by Food Standards Australia New Zealand (FSANZ). Unlike the EU's positive-list system, Australia operates a general safety obligation backed by specific contaminant limits in Standard 1.4.1. This means compliance isn't simply a matter of checking a list — it requires understanding migration pathways, assembling a technical dossier, and knowing which state authority will inspect you when something goes wrong.

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At a glance

Standard reference

Food Standards Code — Std 1.4.1 & 1.4.3

Regulator

FSANZ (standard-setting); state food authorities (enforcement)

Migration test standard

FSANZ guidance — consistent with EFSA simulants

NZ alignment

Joint FSANZ Code applies; MPI enforces in NZ

## Key standards and concepts for food contact materials

### Standard 1.4.1 — Contaminants and Natural Toxicants

Standard 1.4.1 of the Food Standards Code sets maximum levels for contaminants in food, including contaminants that can migrate from packaging or food contact materials. The standard is structured as a permitted maximum level (PML) table — any substance listed with a PML must not be present in food above that concentration. Substances not listed are permitted provided they can be shown not to constitute a hazard to human health. This places a burden of evidence on the manufacturer when using novel materials.

### Standard 1.4.3 — Prohibited and Restricted Plants and Fungi (and Cross-Application to Materials)

While Standard 1.4.3 principally addresses plants and fungi, FSANZ's regulatory framework for food contact materials draws on the Food Standards Code's general safety provision — section 4(1) of the Food Standards Australia New Zealand Act 1991 — which prohibits the sale of food that is unsafe. Materials that cause food to become unsafe by migration of prohibited substances violate this provision. FSANZ has issued guidance notes on specific material categories (flexible packaging, coatings, adhesives) that interpret how the general safety obligation applies.

### Prohibited Substances and the Positive List Divergence from EU 10/2011

Unlike the EU's Regulation 10/2011, which operates as a positive list for food contact plastics (only substances on the list may be intentionally used), Australia does not operate a comprehensive positive list system. Australia applies a general safety obligation plus a prohibited substances approach — substances specifically prohibited by name are banned; everything else is permissible if it does not make food unsafe. This means Australian law is more permissive in structure than EU law, but enforcement of the general safety obligation can reach the same outcome when migration is demonstrable.

### Migration Limits — Specific and Overall Migration

Australia applies migration limits consistent with the general safety framework. Overall migration limits (OML) of 10 mg/dm² (equivalent to the EU 10/2011 OML of 60 mg/kg for a standard 6 dm²/kg food-to-surface ratio) are referenced in FSANZ guidance. Specific migration limits (SMLs) for substances listed in Standard 1.4.1 as contaminants must not be exceeded in food. For novel substances or materials not covered by existing limits, the manufacturer must demonstrate that migration levels do not constitute a health hazard using risk assessment methodology consistent with EFSA or US FDA toxicological approaches.

### Enforcement Split — FSANZ vs State and Territory Food Authorities

FSANZ sets the Food Standards Code but does not enforce it. Enforcement is the responsibility of state and territory food authorities: NSW Food Authority, Safe Food Queensland, Dairy Food Safety Victoria, SA Health, WA Department of Health, NT Environmental Health, Tasmania Public Health Services, and ACT Health. Each jurisdiction has its own enforcement approach, inspection frequency, and penalty structure under the applicable food safety legislation. Importers of food contact hardware must engage with the relevant state authority for the jurisdiction where goods enter or are warehoused.

### New Zealand Equivalence and Divergence

The Food Standards Code applies in both Australia and New Zealand by treaty arrangement — meaning Standards 1.4.1 and associated standards have direct legal effect in New Zealand via the Food Act 2014. However, New Zealand's Ministry for Primary Industries (MPI) is the enforcement body in NZ, and NZ has issued its own guidance notes and import health standards that operate alongside the Code. For food contact materials, practical divergence is limited, but importers supplying both markets should confirm NZ MPI guidance has been reviewed in addition to the FSANZ Code.

## Food contact compliance — from material classification to technical dossier

01

Classify the material category: plastic (identify the polymer type and any additives), metal or alloy (identify alloy composition and any surface coatings), coating or lacquer (identify the resin base and any cross-linking agents), adhesive (identify the base polymer and any residual monomers or solvents), or printing ink (identify the pigment system and any photoinitiators if UV-cured).

02

Check the relevant FSANZ guidance note and Standard 1.4.1 contaminant tables for substances associated with your material type. Identify any substances in your formulation that appear on prohibited lists or that have specific migration limits as contaminants in food.

03

Determine whether migration testing is required based on risk. For established materials (e.g., polyethylene, polypropylene, stainless steel) used in conventional food contact applications, a documented assessment with reference to existing published migration data and compliance with standard 1.4.1 limits may suffice. For novel materials, novel applications (high temperature, fatty food contact), or materials with untested additive packages, laboratory migration testing is required.

04

Engage an accredited testing laboratory to conduct migration testing. Specify the food simulants appropriate for the intended food contact conditions — FSANZ guidance references food simulants consistent with EFSA guidance: aqueous simulant (3% acetic acid for acidic foods, 10% ethanol for alcoholic foods, water for non-acidic aqueous foods), fatty food simulant (iso-octane or olive oil). Test under worst-case conditions of time and temperature for the intended use.

05

Compile a technical dossier documenting: material specification, substance composition, migration test results, comparison of migration levels against Standard 1.4.1 contaminant limits and FSANZ guidance, and a risk assessment conclusion. This dossier is not submitted to FSANZ but must be held by the manufacturer or importer and made available to enforcement authorities on request.

06

If your product is a food contact material hardware device (food processor bowl, kettle lining, reusable container) sold direct to consumers, confirm labelling requirements under the Food Standards Code and the relevant state fair trading law. Claims about food safety or food-grade status must be accurate — false or misleading labelling engages both FSANZ-enforcement risk and ACL misleading conduct provisions.

07

Review compliance on any formulation change. A change in additive supplier, polymer grade, coating system, or pigment is a new material composition requiring re-assessment against Standard 1.4.1. Do not assume an approved formulation carries over to a revised one without fresh documentation.

## Frequently asked questions

### Does Australia follow EU migration limits for food contact plastics?

Australia does not formally adopt EU Regulation 10/2011 or its specific migration limits — the regulatory frameworks are structurally different. EU 10/2011 operates as a positive list with specific migration limits (SMLs) for each listed substance. Australia's system relies on a general safety obligation plus Standard 1.4.1 contaminant limits. In practice, FSANZ guidance references migration limits that are broadly consistent with EU 10/2011 SMLs and FDA thresholds, and compliance with EU 10/2011 is generally considered strong evidence of compliance with Australian requirements — but it is not automatically deemed compliant. Australian food authorities will assess compliance against the Food Standards Code, not against EU law.

### Who enforces food contact compliance in Australia?

FSANZ sets the Food Standards Code but has no direct enforcement power. Enforcement sits with state and territory food authorities under their respective food safety legislation — the Food Act in each jurisdiction. The relevant authority for your business depends on where you manufacture, warehouse, or first sell the goods. For importers, the state or territory where the goods first enter commerce is typically the relevant jurisdiction. The ACCC also has enforcement jurisdiction over misleading representations about food safety under the ACL, and the Australian Border Force can seize non-compliant imported food contact goods under the Customs Act.

### Do New Zealand requirements differ from Australian requirements for food contact materials?

The Food Standards Code applies in New Zealand by virtue of the joint FSANZ treaty arrangement, so the base standards are the same in both countries. However, New Zealand's Ministry for Primary Industries (MPI) is the enforcement body in NZ and has issued its own import health standards and operational guidance that apply to imported food contact goods. Additionally, the Food Act 2014 (NZ) has some procedural differences from Australian state food acts. For most food contact materials, a compliant Australian technical dossier will support NZ compliance — but importers should confirm with NZ MPI guidance rather than assuming full equivalence.

### What materials are outright prohibited for food contact in Australia?

Australia does not publish a single comprehensive prohibited list for food contact materials in the way that EU 10/2011 restricts plastics to listed substances only. However, substances that appear in Standard 1.4.1 with a maximum level of 'not detected' or zero are effectively prohibited in food — any material that causes these substances to migrate into food at detectable levels is non-compliant. Additionally, the general safety provision in the Food Standards Australia New Zealand Act 1991 prohibits placing food in contact with materials that cause the food to become unsafe, which encompasses any material that migrates harmful levels of any substance, whether specifically listed or not. Certain pigment systems (lead-based, cadmium-based) and legacy plasticisers (phthalates DEHP, DBP above Standard 1.4.1 limits) are practical examples of restricted substances under this framework.

**Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult a qualified legal or compliance professional before making decisions.

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