Thailand Pushes Food Contact and Cooking Paper Mandatory Standards Back to June 2027

Two Thai Industrial Standards governing food contact and cooking paper, TIS 2948-2562 (food contact paper) and TIS 3438-2022 (cooking paper), are shifting from voluntary to mandatory, but not on the date originally set. Thailand's Ministry of Industry published both ministerial regulations in the Royal Gazette with an original effective date of June 22, 2026; on March 30, 2026, Thailand filed a WTO Technical Barriers to Trade addendum proposing to push that date back a full year, to June 22, 2027. Once the new date takes effect, products in scope will require product licensing and TIS mark affixation before they can legally be sold in the Thai market, a materially higher bar than the compliance-optional status these standards carry today, but manufacturers and importers now have an additional year to prepare rather than facing a June 2026 deadline.

What Each Standard Actually Covers

TIS 2948-2562 applies to paper, paperboard, and uncolored paper containers intended for use with general foods and hot-filled foods, the category covering everyday food wrapping, bags, and hot-fill paper packaging. TIS 3438-2022 covers cooking paper specifically: paper, paperboard, and paper containers made from virgin pulp alone or combined with synthetic fibers, intended for applications such as filtering hot liquids, warming food, or cooking at temperatures not exceeding 220 degrees Celsius, the category that includes items like parchment-style cooking papers and hot-liquid filter papers. The distinction between the two standards matters for compliance planning: a paper product marketed for general food wrapping falls under one standard's testing regime, while the same base material marketed or used for direct heat exposure up to 220 degrees Celsius falls under the other, meaning a manufacturer selling paper packaging across both use cases needs certification against both standards rather than assuming one covers the other.

The Safety Limits Behind the Mandate

Both standards set controls on heavy metals, including lead, mercury, and cadmium, and on hazardous chemicals used during production, specifically naming optical brighteners and antimicrobial agents as substances subject to prescribed safety limits designed to prevent migration into food at unsafe levels. Materials must meet a "food-contact-grade quality" bar under both standards rather than a general industrial paper specification. This distinction matters commercially because ordinary industrial paper and paperboard, produced to standards intended for packaging that never touches food directly, can and does contain higher levels of these same substances than a food-contact-grade equivalent, meaning a supplier's general paper-quality certification is not a substitute for confirming food-contact-grade sourcing specifically.

From Voluntary to Mandatory: What Actually Changes

Today, a manufacturer or importer of food contact or cooking paper can still reference TIS 2948-2562 or TIS 3438-2022 as a voluntary quality benchmark without a legal requirement to certify against it. As of June 22, 2027, both standards will require formal product licensing and physical TIS mark affixation on qualifying products before market sale, converting what has been a marketing differentiator into a mandatory pre-sale gate. A product currently selling in Thailand on the strength of a general food-safety declaration, without a TIS certification, will need that certification once the standards become mandatory if it falls within either standard's scope.

Why Paper Packaging Specifically Needed Its Own Mandatory Standard

Paper and paperboard food packaging present a different risk profile than plastic or metal packaging, one that had gone comparatively under-regulated in Thailand relative to more established categories like ceramics and enamelware. Recycled fiber content, chemical treatments used to add grease resistance or wet strength, and printing inks and coatings applied to the outer surface of paper packaging can all introduce contaminants capable of migrating into food, particularly for hot-filled or hot-liquid applications where elevated temperature accelerates migration. TIS 2948-2562 and TIS 3438-2022 close that gap for the two paper-based categories now covered, general food-contact paper and cooking paper specifically rated for higher-temperature use, by requiring the same kind of formal, tested compliance already expected of other packaging categories.

What Certification Actually Requires From Manufacturers

Moving from voluntary to mandatory status will mean a manufacturer or importer of qualifying paper products can no longer rely on an internal quality declaration alone. Product licensing under the relevant TIS standard requires submitting the product for testing against the standard's specific heavy-metal and hazardous-chemical limits, covering lead, mercury, cadmium, and controls on substances like optical brighteners and antimicrobial agents used in paper processing, before the product can carry the TIS mark. Once licensed, that TIS mark must be physically affixed to the product before it is sold in Thailand, giving inspectors and retailers a visible compliance signal rather than relying on paperwork alone at the point of sale. A manufacturer currently selling into the Thai market under the still-voluntary regime should use the extra year the extension provides to treat this transition as a real certification project well ahead of the new June 2027 deadline, not a last-minute relabeling exercise, since the underlying requirement is a tested and licensed product rather than a self-declared one.

Part of a Larger Food Contact Material Overhaul

This mandate did not arrive in isolation. Thai FDA opened a public consultation on February 12, 2026 proposing a much broader restructuring of Thailand's food contact material regulation, expanding coverage beyond the ceramics and enamelware focus of the original 1985-era rule to include metals, glass, and paper-based materials as their own regulated categories, with new migration-based safety requirements and specific controls on bisphenols, epoxy derivatives, and PFAS. The June 22 mandatory paper standards are the piece of that broader modernization that has already reached enforceable status; the metals, glass, and expanded chemical-migration rules remain in the consultation and drafting stage, discussed at greater length in our separate guide to Thailand's food contact packaging regulation.

How Thailand's Timing Compares to Global Packaging Scrutiny

Thailand's move to control PFAS, bisphenols, and epoxy derivatives in food packaging, and to make paper-specific safety standards mandatory rather than voluntary, tracks a broader global regulatory direction rather than running ahead of or behind it in isolation. Multiple major markets have tightened rules on exactly these substance classes in food-contact packaging in recent years, and a brand already managing PFAS or bisphenol compliance for its EU or US-bound packaging is likely to find Thailand's direction of travel familiar even where the specific numeric limits and certification mechanics differ. That makes this a reasonable moment for multinational brands to audit Thai-market packaging against the same substance watchlist they are likely already tracking for other jurisdictions, rather than treating Thailand's rules as a wholly separate compliance exercise.

Brands using paper-based packaging or cooking paper products in the Thai market should treat the June 22, 2027 deadline as a firm planning date rather than a distant concern, since certification and TIS mark affixation take real lead time to arrange. DeeMED reviews packaging material compliance as part of our broader GMP requirements and food registration work for manufacturers and importers entering the Thai market.