Food Contact Materials Regulations and Compliance: South Africa, the EU and the USA

Categories: FSMS
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About Course

Your EU customer wants a declaration of compliance. Your local buyer wants a ’South African food grade certificate’. Only one of those documents exists. This food contact materials course teaches the law behind both requests for South Africa, the EU and the United States, from the primary texts.

Who it is for: technical, QA, regulatory and export staff at packaging converters, food manufacturers and exporters who approve packaging or answer customers about it. No site of your own is needed.

What you will be able to do:

  • Name the rules that apply to a pack in each market, by number and date.
  • Read a supplier’s compliance file and name each gap with the article or section behind it.
  • Tell a customer what South African law does and does not require, without overclaiming.
  • Build a compliance file per pack and keep it current.

What it covers: in South Africa, Act 54 of 1972, R638 of 2018 and GN R.879 of 2011. In the EU, Regulation (EC) 1935/2004, the GMP Regulation (EC) 2023/2006, Regulation (EU) 10/2011 as amended to 2026, recycled plastics under Regulation (EU) 2022/1616, bisphenols under Regulation (EU) 2024/3190 as corrected, and the PPWR food contact limits that have applied since 12 August 2026. In the United States, 21 CFR Parts 174 to 179 and the Food Contact Substance Notification programme.

What you take back to work: the food contact compliance file checker. It lists what each market requires for a pack, flags what is missing or out of date, and exports an Excel workbook. You also earn a QR-verified certificate.

Time and assessment: 12 hours, online and self-paced: 35 lessons in 7 modules, 24 case activities on Mzansi Pack, ASC’s training converter, with model answers, a knowledge check and a game per module, a timed and proctored final of 30 questions drawn from 65, and a practical assignment: the compliance file and covering note for an EU lidding film, or for one of your own packs. Pass mark 70 percent, three attempts, written feedback. The certificate is released once every assessment is passed and your course review is in.

R2 450, no VAT charged. Set that against one EU order refused because the supplier declaration predates Regulation (EU) 2025/351, or one lot of ready meals rejected for an ink taint, which Article 3(1)(c) of Regulation (EC) 1935/2004 treats as a breach even when every migration limit is met.

What Will You Learn?

  • Name the rules that apply to a pack in each market
  • Read a supplier’s compliance file and see what is missing
  • Explain correctly to a customer what South African law does and does not require
  • Build and maintain a compliance file per pack using the food contact compliance file checker

Course Content

Module 1: South Africa: Act 54 of 1972, R638 of 2018 and the 2011 BPA bottle prohibition
What South African law actually requires of food contact packaging: the outcome duties in Act 54 of 1972 and R638 of 2018, the narrow 2011 BPA bottle prohibition (GN R.879), and how to say all of this to a customer without overclaiming.

  • What South African law says about food contact, and what it does not
  • The Foodstuffs Act: package, sale and the offences that reach packaging
  • R638 of 2018: what the hygiene regulations ask of containers
  • The 2011 BPA infant feeding bottle prohibition, and how to cite it
  • Saying it right: what South African law does and does not require
  • Module 1 knowledge check
  • Law or myth?

Module 2: EU framework: Regulation (EC) 1935/2004, the GMP Regulation (EC) 2023/2006 and the PPWR
The EU framework, Regulation (EC) 1935/2004: scope, the Article 3 safety test, labelling, declarations and traceability. How the law reaches inks and adhesives without a Union list. The GMP Regulation with its 2025 additions, and the PPWR limits on PFAS and heavy metals that have applied since 12 August 2026.

Module 3: Plastics: Regulation (EU) 10/2011 as amended
Regulation (EU) 10/2011 as amended to 2026. Scope and definitions, the Union list and the 2025 purity rules, overall and specific migration, metals and primary aromatic amines, multi-layers and functional barriers, and how to check a supplier’s declaration.

Module 4: Recycled plastics: Regulation (EU) 2022/1616
Regulation (EU) 2022/1616 for recycled plastic. Why mechanically recycled PET cannot go into an oven or microwave tray, how processes are authorised and registered, what the container label and the declarations must show, and whether a food customer can use rPET from a new local recycler.

Module 5: Bisphenols: Regulation (EU) 2024/3190 as corrected
Regulation (EU) 2024/3190 as corrected by Regulation (EU) 2026/250. Why the EU prohibited BPA, the seven material groups it reaches, the two Annex II derogations, the transitional dates, declarations and testing. A bisphenol check on a converter’s inks, adhesives and coatings closes the module.

Module 6: United States: 21 CFR Parts 174 to 179 and the Food Contact Substance Notification programme
How US law decides whether a packaging component is a food additive, how to find a substance in 21 CFR Parts 175 to 179, how an FCN works, and the threshold of regulation, GRAS and prior sanction routes. You finish by writing a US compliance statement for a South African pack.

Module 7: Building a compliance file per pack
One pack, one file. What the file holds in each market, who keeps which documents, how to read a supplier’s file for gaps, how to keep it current, and the workshop on Mzansi Pack’s lidding film.

Assignment, final assessment and course review
Your practical assignment on your own site or on Mzansi Pack, then the final assessment. Your certificate is released when every assessment is passed and your course review is submitted.

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