SOUTH KOREA FCM REGULATORY UPDATE
South Korea’s Ministry of Food and Drug Safety (MFDS) issued Notification No. 2026-24 on March 27, 2026, revising the Standards and Specifications for Utensils, Containers and Packages. The revisions update DEHP and DEHA migration limits for PVC, introduce recognition criteria for physically recycled polypropylene, and clarify regulatory terminology. Companies supplying materials or food contact articles to South Korea should review the changes as part of their Korea FCM compliance assessment.
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Jump to the key revisions, implementation dates and compliance considerations.
Korea FCM Standards: Key Changes at a Glance
The revision is based on MFDS Notification No. 2026-24. It affects PVC specifications, the recognition of physically recycled PP raw materials, and the interpretation of terminology used in South Korea’s food contact material standards.
| Regulatory Area | Key Revision | Applicable Date | Relevant Businesses |
|---|---|---|---|
| DEHP in PVC | Migration limit changed from ≤1.5 mg/L to not detected. | March 27, 2027 | PVC material suppliers, converters and food packaging businesses |
| DEHA in PVC | The limit remains ≤18 mg/L, but DEHA must be not detected in cling wraps. | March 27, 2027 | PVC cling-wrap material suppliers and manufacturers |
| Physically Recycled PP | Recognition criteria have been added for eligible physically recycled PP raw materials. | March 27, 2026 | Recycled PP suppliers, recycling operators and packaging manufacturers |
| Terminology and Structure | A terminology explanation section has been added, and the article structure has been reorganized. | March 27, 2026 | Material suppliers, manufacturers, importers and testing institutions |
Revised DEHP and DEHA Migration Limits for PVC
To align the PVC specifications with the general manufacturing standards prohibiting the use of certain plasticizers and to clarify how the requirements apply, MFDS revised the migration limits for DEHP and DEHA in PVC materials.
| Test Item | Previous Migration Limit | New Migration Limit |
|---|---|---|
| Di-(2-ethylhexyl) phthalate (DEHP) | ≤1.5 mg/L | Not detected |
| Di-(2-ethylhexyl) adipate (DEHA) | ≤18 mg/L | ≤18 mg/L; DEHA must not be detected in cling wraps |
The revised DEHP and DEHA limits are subject to a 12-month transition period and will be formally enforced from March 27, 2027.
Recognition Criteria for Physically Recycled Polypropylene
The previous standards recognized safety requirements for physically recycled PET. The revised standards expand the scope by introducing recognition criteria for physically recycled polypropylene.
To reduce contamination risks arising during use and disposal, recycled PP input materials must meet specified preconditions:
Single-material input: the input materials must be made of pure PP.
Controlled collection: the PP must be recovered through a closed and controlled system that prevents exposure to non-food contamination sources.
Printing restrictions: the bottle surface must not be directly printed, except where alkali-separable ink is used.
No adhesives: adhesives must not be used on the eligible input materials.
Cleaning requirements: the materials must be thoroughly cleaned to ensure that impurities are absent.
The inclusion of recycled PP does not automatically mean that all post-consumer PP is acceptable. Businesses should first determine whether their collection system and input materials meet the recognition criteria.
New Terminology Explanations and Reorganized Structure
To reduce differences in interpretation among industry stakeholders and testing institutions, the revised standards add a dedicated terminology explanation section to the general provisions.
Definitions are provided for key terms including monomer, copolymer, physically recycled synthetic resin raw materials, infant rubber products, and potassium permanganate consumption. MFDS has also reorganized and streamlined the article structure.
Effective Dates and Recommended Compliance Actions
Most of the revised standards, including the terminology explanations and recognition criteria for physically recycled PP, took effect on March 27, 2026. The revised DEHP and DEHA migration limits for PVC will apply from March 27, 2027.
Review material applicability: identify whether supplied raw materials, intermediate materials or finished food contact articles fall within the affected PVC or recycled PP requirements.
Check formulations and specifications: PVC-related businesses should review plasticizer use and applicable migration specifications during the transition period.
Assess recycled PP inputs: confirm whether collection systems, printing, adhesives and cleaning practices satisfy the new recognition criteria.
Update technical documentation: align specifications, test plans and supply-chain information with the revised Korean standards.
Frequently Asked Questions
When do the revised DEHP and DEHA migration limits apply?
The revised limits apply from March 27, 2027. MFDS provided a 12-month transition period for these PVC-related changes.
Does the revision allow all physically recycled PP for food contact use?
No. The revision establishes recognition criteria for physically recycled PP, including requirements relating to material purity, controlled collection, printing, adhesives and cleaning.
How REACH24H Can Support Korea FCM Compliance
REACH24H can support material suppliers, manufacturers, importers and food contact businesses in evaluating applicable Korean requirements. Learn more about our Korea food contact material compliance service.
Regulatory applicability assessment: identify relevant Korean standards according to the material, composition and intended food contact use.
Compliance gap review: compare product information, specifications and supporting documents against applicable requirements.
Testing and documentation support: assist with compliance testing strategies and the preparation or review of relevant technical documentation.
Need support with Korea FCM compliance?
Submit your material, composition and intended-use information to assess the applicable Korean standards and compliance pathway.
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