Food Contact Material & Recycled Plastic

Korea MFDS FCM Proposals: Infant Rubber, Recycled PP & PVC

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SOUTH KOREA FCM REGULATORY PROPOSALS

On January 8, 2026, South Korea’s Ministry of Food and Drug Safety issued Announcements No. 2026-008 and No. 2026-009 proposing amendments to the Standards and Specifications for Utensils, Containers and Packages. The proposals covered infant rubber products, physically recycled polypropylene and PVC plasticizer limits. The consultation has since closed, and part of the proposals has been finalized. Material suppliers and manufacturers can review the changes as part of their Korea FCM compliance assessment.

   Announcements No. 2026-008 and 2026-009       Consultation Closed March 9, 2026       Infant Rubber Products      Recycled PP and PVC   

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Review the regulatory status, proposed requirements and practical compliance considerations.

Regulatory Status Update

The public consultation period for both proposals ended on March 9, 2026.

MFDS subsequently incorporated the recycled PP, PVC migration-limit and terminology changes from Announcement No. 2026-009 into MFDS Notification No. 2026-24, issued on March 27, 2026. The infant-rubber requirements discussed below originated in the separate Announcement No. 2026-008 and should be checked against the latest official text before being treated as final.

TopicOriginal ProposalCurrent Status Covered by This Article
Infant rubber productsAnnouncement No. 2026-008Presented below as a proposed requirement; verify the latest MFDS text before implementation.
Physically recycled PPAnnouncement No. 2026-009Subsequently incorporated into Notification No. 2026-24.
DEHP and DEHA limits for PVCAnnouncement No. 2026-009Subsequently incorporated into Notification No. 2026-24, with the revised limits applying from March 27, 2027.

Proposed Standards for Infant Rubber Products

Announcement No. 2026-008 proposed separate standards and specifications for infant rubber products, including products such as rubber teething toys and rubber straws. The proposal would apply specifications comparable to those used for infant rubber pacifiers.

Residue Specifications

Test ItemProposed SpecificationApplication Note
Lead≤10 mg/kg
Cadmium≤10 mg/kg
2-MercaptoimidazolineNot detectedApplied only to rubber containing chlorine
1,3-Butadiene≤1 mg/kgApplied only where 1,3-butadiene accounts for 50% or more of the base polymer

Migration Specifications

Test ItemProposed Specification
Lead≤1 mg/L
Overall migration≤40 mg/L
Phenol≤5 mg/L
Formaldehyde≤4 mg/L
Zinc≤1 mg/L
N-Nitrosamines            Sum of N-nitrosodimethylamine, N-nitrosodiethylamine, N-nitrosodi-n-propylamine, N-nitrosodi-n-butylamine, N-nitrosopiperidine, N-nitrosopyrrolidine and N-nitrosomorpholine            ≤0.01 mg/kg
N-Nitrosatable substances            Sum of the corresponding nitrosatable substances specified in the proposal            ≤0.1 mg/kg

The proposal also introduced a total volatile matter requirement under which the total volatile content of infant rubber products would not exceed 0.5%.

Recognition Standards for Physically Recycled PP

Announcement No. 2026-009 proposed expanding the permitted physically recycled synthetic resin raw materials from PET to include physically recycled polypropylene.

1. Raw Material Admission Requirements

Input materials would need to consist of a single PP material and be recovered through a controlled closed-loop system that prevents exposure to non-food contamination sources. The proposal also addressed direct printing, adhesives and thorough cleaning of the recovered materials.

2. Recycling Process Control

The recycling process would need to be independently controlled, including critical operating parameters such as temperature and pressure. The proposal called for appropriate standard operating procedures and validated testing methods as part of the supporting safety documentation.

3. Recognition Application Documentation

The proposed application documentation included test reports issued by accredited institutions, information on the product’s intended use, usage temperature and contacted food types, as well as supply-chain information, production-process documentation and quality-assurance evidence.

Proposed DEHP and DEHA Migration Limits for PVC

The existing general manufacturing standards prohibited the use of di-(2-ethylhexyl) phthalate in utensils, containers and packages and di-(2-ethylhexyl) adipate in cling wraps, except where migration into food was not possible. Announcement No. 2026-009 proposed aligning the PVC migration specifications with these restrictions.

Test ItemPrevious Migration LimitProposed Migration Limit
Di-(2-ethylhexyl) phthalate (DEHP)≤1.5 mg/LNot detected
Di-(2-ethylhexyl) adipate (DEHA)≤18 mg/L≤18 mg/L; not detected in cling wraps

These PVC changes were subsequently included in MFDS Notification No. 2026-24. The revised migration limits are scheduled to apply from March 27, 2027.

What Material Suppliers and Manufacturers Should Review

  • Infant rubber products: distinguish the requirements proposed under Announcement No. 2026-008 from requirements already included in the current consolidated standards.

  • Physically recycled PP: review input-material purity, collection systems, printing, adhesive use, cleaning processes and supporting technical information.

  • PVC materials: assess DEHP and DEHA use, product specifications and migration-testing arrangements before March 27, 2027.

  • Technical documentation: keep material composition, intended use, contacted food types, processing conditions and supply-chain information consistent.

How REACH24H Can Support Korea FCM Compliance

REACH24H can support material suppliers, manufacturers and importers in identifying applicable Korean requirements and reviewing product information against the latest regulatory standards. Learn more about our Korea food contact material compliance service.

  • Applicability assessment: identify the Korean requirements relevant to the material, composition and intended food contact use.

  • Compliance gap review: review specifications, formulation information and supporting documents against applicable requirements.

  • Testing and documentation support: assist with compliance testing strategies and 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.

Recommended Reading

Official Resources

REACH24H FCM Compliance Team

Written by

REACH24H FCM Compliance Team

REACH24H

The food contact materials (FCM) team of REACH24H specializes in global regulatory compliance for food contact and recycled materials. Covering markets including China, the US, the EU, Canada and MERCOSUR, we bring over 10 years of proven experience in new substance applications with in-depth knowledge of category-specific requirements. Our services span the entire product lifecycle, from raw materials, new ingredient applications and intermediates to end-product compliance.

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