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# Australia Food Standards for Packaging Materials: FSANZ Compliance for Electronics-Adjacent Products

Australia's food contact materials framework is principle-based rather than positive-list — which means less upfront prescription but more burden on manufacturers to demonstrate safety. FSANZ Standard 1.4.3, the AICIS industrial chemicals regime, and state-level food enforcement create a layered compliance picture. For electronics companies making smart packaging, food-safe seals, connected kitchen devices, or packaging with embedded electronics, understanding where food law and product safety law intersect is essential before you go to market.

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At a glance

Governing standard

FSANZ Standard 1.4.3; Australia New Zealand Food Standards Code

Chemical scheme

AICIS (Industrial Chemicals Act 2019)

OML benchmark

10 mg/dm² (EU 10/2011 in practice)

BPA status

Permitted (no general ban)

Corporate penalty (state)

Up to AUD $500,000 per offence

## Key concepts in Australian food packaging compliance

### FSANZ and the Australia New Zealand Food Standards Code

Food Standards Australia New Zealand (FSANZ) is the joint statutory authority established under the Food Standards Australia New Zealand Act 1991 that develops and administers the Australia New Zealand Food Standards Code. The Code applies in all Australian states and territories and in New Zealand through parallel domestic legislation. FSANZ Standard 1.4.3 covers processing aids — substances used in food production that may leave residues in the final food — and is the primary entry point for evaluating whether a packaging substance has been addressed in the Code. Unlike the EU's Regulation (EC) No 1935/2004 framework, Australia does not maintain a single positive list of approved food contact materials; instead, the system is principle-based, requiring that packaging does not transfer substances to food at levels that could endanger human health or result in an unacceptable change in the food's composition.

### Migration Limits and the Absence of a National Positive List

Australia's food contact materials framework sets an overarching migration limit — packaging must not transfer substances into food at levels that present a risk to human health — but does not enumerate permitted substances in a comprehensive positive list equivalent to the EU's Regulation (EU) No 10/2011 on plastic food contact materials. In practice, Australian food manufacturers and packaging suppliers frequently reference EU 10/2011 migration limits as the relevant benchmark, since the FSANZ Code is silent on specific migration thresholds for most plastics additives. Migration testing is conducted using food simulants (water, 3% acetic acid, 10% ethanol, olive oil or synthetic triglycerides) at time-temperature conditions representative of the food's intended use and shelf life. The overall migration limit (OML) referenced in Australian practice is 10 mg/dm², consistent with the EU standard.

### BPA (Bisphenol A) Status in Australian Food Packaging

Bisphenol A (BPA) is a plasticiser and epoxy resin monomer widely used in polycarbonate food containers and the internal lining of metal cans. FSANZ conducted a thorough safety assessment of BPA in 2014–2016 and concluded that dietary exposure to BPA from food contact materials does not pose a public health risk to adults. As a result, Australia has not enacted a general BPA ban equivalent to the EU's 2011 prohibition on BPA in infant feeding bottles (Commission Directive 2011/8/EU) or the EU's 2022 restriction under Regulation (EU) 2022/1259. However, BPA is not included in FSANZ Standard 1.4.3 as an approved processing aid, and the European Food Safety Authority's (EFSA) 2023 opinion — which drastically lowered the tolerable daily intake to 0.2 ng/kg body weight/day — is driving reformulation globally. Products sold in both the EU and Australia should align to the more restrictive EU position to avoid dual supply chains.

### AICIS and New Chemical Notifications for Packaging Additives

The Australian Industrial Chemicals Introduction Scheme (AICIS), established under the Industrial Chemicals Act 2019 and replacing the former NICNAS scheme from 1 July 2020, regulates the introduction of industrial chemicals into Australia — including chemical substances used as packaging additives, coatings, inks, adhesives, and processing aids. If a packaging additive, UV stabiliser, antioxidant, slip agent, or other functional chemical is not already listed on the AICIS Inventory and does not qualify for an exemption, the importer or manufacturer must notify AICIS before introduction. The notification category (exempted, reported, or evaluated) depends on volume and hazard profile. Penalties for unnotified introduction can reach AUD $6.3 million for corporations. Companies importing packaging materials with novel chemistry — including new bio-based or recycled-content additives — should screen the AICIS Inventory as a mandatory pre-market step.

### Recycled Plastics in Food Packaging: Migration Testing Requirements

The use of recycled plastic content in food contact materials is growing due to sustainability mandates and packaging regulations, but recycled materials introduce contamination risks that virgin plastics do not. Australian food law does not explicitly prohibit recycled plastics in food contact applications, but the principle that packaging must not endanger health means that recycled content must be demonstrated safe through migration testing and, in many cases, challenge testing with a defined set of surrogate contaminants. The European Food Safety Authority's (EFSA) recycled plastics evaluation framework — which requires decontamination efficiency testing against a surrogate set — is widely adopted in Australia as the practical standard. Mechanical recycling processes for PET (rPET) are most commonly evaluated; chemical recycling outputs are treated as equivalent to virgin material if the process is validated. FSANZ has not published domestic guidelines on recycled food contact material safety, making international frameworks the default reference.

### State and Territory Enforcement and Penalty Exposure

While FSANZ develops the national food standards, enforcement is the responsibility of state and territory food regulatory agencies — Food Standards NSW, DHHS Victoria, Queensland Health, SafeWork SA, and their equivalents. These agencies conduct market surveillance, respond to complaints, and prosecute breaches of the respective state Food Acts, which incorporate the Australia New Zealand Food Standards Code by reference. Corporate penalties for selling food in packaging that contaminates the food or is otherwise non-compliant can reach AUD $500,000 per offence under state legislation. Recalls are coordinated through FSANZ's food recall program, and a packaging-caused recall is highly visible — Food Standards Australia New Zealand publishes all recalls publicly. For electronics-adjacent products (food-safe seals, smart packaging with electronics, connected kitchen devices), the intersection of packaging law and product safety law creates layered compliance obligations.

## How to achieve FSANZ food packaging compliance

01

Determine which FSANZ standards apply to your specific packaging material and food contact application. Standard 1.4.3 covers processing aids; Standard 3.2.3 covers food premises and equipment that contacts food during production. For consumer packaged food products, the overarching requirement in Standard 1.1.1 that food must not be unsafe applies to the packaging. If your product contains a novel functional chemical in the packaging layer, check whether it is captured as a processing aid under 1.4.3 or falls outside any specific FSANZ standard — the latter situation means you must justify safety on general principles.

02

Review the Australia New Zealand Food Standards Code for any migration limits that specifically apply to your packaging substrate, additive, or coating. Search the FSANZ website for your chemical by name or CAS number. Where the Code is silent — which is common for specific plastics additives — consult EU Regulation (EU) No 10/2011 Annex I (the positive list) and Annex II (restricted substances) as the practical benchmark, since this is the approach taken by Australian food manufacturers and their technical advisors.

03

Commission migration testing from an accredited laboratory using food simulants and time-temperature conditions appropriate for your food category. Simulant A (water) for aqueous foods, Simulant B (3% acetic acid) for acidic aqueous foods, Simulant C (10% ethanol) for alcoholic foods, and Simulant D (synthetic triglycerides or olive oil) for fatty foods. Test at the worst-case combination of temperature and contact time your packaging will experience across the supply chain, including storage, transport, and consumer use. Document and retain all test reports as compliance evidence.

04

Screen the AICIS Inventory at aicis.gov.au for every industrial chemical in your packaging system — including primary packaging, secondary packaging coatings, inks, adhesives, and functional additives. Use the AICIS Chemical Search Tool. If a substance is not on the Inventory and no exemption applies, engage an AICIS-registered introducer or submit a notification before importing or manufacturing the product in Australia. The AICIS categorisation process (exempted, reported, or evaluated) determines pre-market assessment requirements and timelines.

05

Review BPA and phthalate restrictions for your specific product category and target market. While Australia has not enacted a general BPA ban, infant formula packaging and products marketed to infants carry heightened scrutiny — FSANZ Standard 2.9.1 governs infant formula and any packaging-to-product migration into this category will be assessed against conservative health-based guidance values. For phthalates including DEHP, DINP, and DIDP, check both AICIS inventory status and EU REACH Regulation Annex XVII restrictions if you export to the EU.

06

Ensure recycled content in food contact packaging meets decontamination and migration safety requirements. If using rPET or other recycled polymers, obtain the recycler's decontamination validation data — typically based on EFSA's challenge test methodology using surrogate contaminants at defined challenge concentrations. Retain this data as part of your food safety management system documentation. Communicate recycled content and decontamination validation status to your food manufacturing customers, who bear the primary compliance obligation under Australian food law.

07

Submit a FSANZ Application if you need to establish a new food contact substance permission under the Australia New Zealand Food Standards Code. Applications are lodged through the FSANZ Application Handbook process and require supporting toxicological and exposure data. FSANZ publishes a call for submissions and consultation period before making a final assessment. This pathway is relevant when a novel bio-based packaging material or a new functional additive has no existing permission in the Code and cannot be justified solely on general safety principles.

## Frequently asked questions

### Does FSANZ regulate food packaging materials in Australia?

FSANZ sets the overarching food safety standard that packaging must not make food unsafe or transfer substances at harmful levels, through the Australia New Zealand Food Standards Code. However, Australia does not have a single pre-market approval list for food packaging materials equivalent to the EU's positive list system under Regulation (EU) No 10/2011. FSANZ Standard 1.4.3 addresses processing aids — substances used in production that may leave residues — and specific restrictions apply to certain substances. For most packaging chemicals, compliance is assessed on general safety principles, with EU migration limits widely used as the practical benchmark by Australian industry.

### Is BPA banned in Australian food packaging?

No — Australia has not enacted a general BPA ban in food packaging. FSANZ assessed BPA safety in 2014–2016 and concluded that dietary exposure from food packaging does not pose a public health risk at levels found in the Australian food supply. BPA remains permitted in food contact applications including polycarbonate containers and epoxy can linings. However, BPA is banned in infant feeding bottles across the EU, Canada, and some US states, and the European Food Safety Authority's 2023 revised tolerable daily intake of 0.2 ng/kg body weight/day is driving global reformulation. Manufacturers selling into both markets should consider BPA-free formulations to avoid dual supply chains.

### What migration testing is required for plastic food packaging in Australia?

FSANZ does not mandate a specific migration testing protocol or accreditation scheme, but overall migration and specific migration must be demonstrably within safety-based limits. In practice, the EU framework — testing with food simulants A (water), B (3% acetic acid), C (10% ethanol), and D2 (vegetable oil or synthetic triglycerides) at worst-case time-temperature conditions, with an OML of 10 mg/dm² and substance-specific migration limits from EU 10/2011 Annex I — is the reference standard used by Australian food packaging suppliers and their customers. Laboratories accredited by the National Association of Testing Authorities (NATA) perform these tests to ISO 17025.

### How does AICIS interact with FSANZ for packaging chemical approvals?

AICIS and FSANZ regulate packaging chemicals under separate legislative frameworks that operate in parallel, not sequentially. AICIS (under the Industrial Chemicals Act 2019) regulates the introduction of industrial chemicals into Australia — if a packaging additive is not on the AICIS Inventory and no exemption applies, it cannot be legally introduced regardless of its food safety status. FSANZ (under the Food Standards Australia New Zealand Act 1991) regulates whether the packaging is safe for food contact under food law. A substance must clear both regimes: AICIS clearance for introduction, and FSANZ compliance for food contact safety. A substance listed on the AICIS Inventory may still be non-compliant under FSANZ food standards if it migrates into food at harmful levels.

**Disclaimer:** Educational resource only. Regulatory requirements change. Consult a qualified compliance specialist before making decisions.

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