1. “Food grade” is a category statement, not a SKU conclusion
A general specification or supplier statement can begin material screening, but it does not answer whether that pouch is suitable for the actual durian-snack formulation. Migration depends on the food, contact area, time, temperature and material construction.
The decision should connect the material identity, structure code, converter, ink, adhesive, contact side and lot to the real SKU and use case. A trade name or quotation line should not stand in for the complete evidence set.
2. Thai and EU legal routes need separate checks
Thailand's Food Division groups Ministry of Public Health Notification No. 435 B.E. 2565 on plastic food-packaging qualities and standards with official explanations, testing guidance and safety-assessment routes.
For an EU destination, the team must also review destination rules, particularly Regulation (EU) No 10/2011 and relevant amendments. Meeting one jurisdiction's requirements should not be extended into a conclusion for another market without a scope review.
3. Food-contact safety is not recyclability
The Journal's PPWR article addresses packaging and recyclability. This article addresses transfer of constituents from plastic to food and the compliance documentation behind that assessment. The two lanes can affect the same pouch but answer different questions.
A recycling symbol, circular-content statement or design-for-recycling assessment does not replace food-contact suitability evidence. Conversely, a food-contact Declaration of Compliance does not prove that the pouch is recyclable.
4. A Declaration of Compliance needs a supporting file
Annex IV to Regulation (EU) No 10/2011 specifies content including the issuer, manufacturer or importer, material identity, date, compliance confirmation, information on restricted substances and use specifications.
The same regime requires supporting documentation for enforcement authorities. Substantiation may use migration testing, calculations, modelling, other analysis or scientific reasoning where applicable. A one-page declaration should therefore trace back to data that support its statements.
5. Testing must match the food and intended use
EU rules link food or food-simulant selection to food properties, while test time and temperature should reproduce expected migration from foreseeable use as closely as possible.
For a durian-snack pouch, the technical team should define the formula or food character, shelf life, filling and storage temperatures, contact side, any heating and the contact area before deciding whether a report covers the use. Changes to formula, structure, adhesive, ink, supplier or process can trigger a new assessment of evidence validity.
6. 16 September 2026 is a transition milestone, not a stock-clearing day
Commission Regulation (EU) 2025/351 was published in the Official Journal on 24 February 2025 and changes several plastic food-contact rules. Article 4 says qualifying materials and articles that complied with the prior rules and were first placed on the market before 16 September 2026 may continue to be placed on the market until stocks are exhausted.
First placing on the market is therefore more relevant than a report print date or box-opening date. Teams need material identity, dates, stock status and placement records; they should not assume every document or pouch expires simultaneously on that date.
7. Seven layers of a Food-Contact Packaging Evidence File
This framework helps product teams, factories, converters and importers see which evidence answers which question. It is not an approval or legal guarantee.
- SKU and use identity: formula, food character, shelf life, time and temperature
- Packaging construction: layers, thickness, contact side, inks, adhesives and coatings
- Declaration of Compliance: issuer, material identity, date, scope and restrictions
- Supporting documentation: substance information, assessments, calculations and scientific reasoning
- Migration evidence: method, sample, simulant, time, temperature and SKU coverage
- Traceability and change control: converter, lot, artwork, supplier and construction changes
- Market and lot release: destination rule, transition status, shipment identity, reviewer and decision
8. Thai origin and the claim boundary
Thai durian origin gains value when the trail can run from ingredient and formula to pouch, document version, manufacturer and lot. Origin itself does not establish food-contact-material compliance.
Siam Diamond Journal uses official sources only to explain evidence-file design. It does not state that Siam Diamond has an EU-compliant pouch, Declaration of Compliance or product-specific migration report. This is not legal advice.
