UGANDA STANDARD  
  DUS 1659  
Second  Edition  
2022 -mm-dd 
 
 
 Reference number  
DUS 1659 : 2022 
© UNBS 2022   
  
Materials in contact with food — Requirements for packaging 
materials  
 DUS 1659: 2022  
ii © UNBS 2022 – All rights reserved  
 Compliance with this standard does not, of itself confer immunity from legal obligations  
A Uganda Standard does not purport to include all necessary provisions of a contract. Users ar e 
responsible for its correct application  
© UNBS 2022   
All rights reserved. Unless otherwise specified, no part of this publication may be reproduced or utilised in any 
form or by any means, electronic or mechanical, including photocopying and microfilm, w ithout prior written 
permission from UNBS.  
Requests for permission to reproduce this document should be addressed to  
The Executive Director  
Uganda National Bureau of Standards  
P.O. Box 6329  
Kampala  
Uganda  
Tel: +256 41 4 333 2 50/1/2/3  
Fax: +256 41 4 286 123  
E-mail: info@unbs.go.ug  
Web: www.unbs.go.ug  DUS 1659: 2022  
© UNBS 2022  – All rights reserved  iii 
 Contents  Page 
Foreword  ................................ ................................ ................................ ................................ ............................  iv 
1 Scope  ................................ ................................ ................................ ................................ ......................  1 
2 Normative references  ................................ ................................ ................................ ............................  1 
3 Terms and definitions (mandatory)  ................................ ................................ ................................ ..... 1 
4 Requirements  ................................ ................................ ................................ ................................ .........  3 
4.1  General  ................................ ................................ ................................ ................................ ...................  3 
4.2 Raw materials  ................................ ................................ ................................ ................................ ...............  3 
4.2.1 General  ................................ ................................ ................................ ................................ .......................  3 
4.2.2 Identification of raw materials  ................................ ................................ ................................ ..................  3 
4.2.3 Colourants  ................................ ................................ ................................ ................................ ..................  3 
4.2.4 Rework materials  ................................ ................................ ................................ ................................ ....... 4 
4.7 Migration  ................................ ................................ ................................ ................................ .......................  5 
4.7.1 General  ................................ ................................ ................................ ................................ .......................  5 
4.7.2  Plastic materials  ................................ ................................ ................................ ................................ .... 5 
4.7.3  Packaging materials made of alloys ................................ ................................ ................................ .... 5 
4.7.4  Glass packaging materials  ................................ ................................ ................................ ...................  6 
4.7.5   Ceramic packaging materials  ................................ ................................ ................................ ..............  6 
4.7.6 Non -regulated substances  ................................ ................................ ................................ .......................  7 
5 Hygiene  ................................ ................................ ................................ ................................ .............................  7 
6 Packaging  ................................ ................................ ................................ ................................ .........................  8 
7 Weights and measures  ................................ ................................ ................................ ................................ ... 8 
8 Lab elling  ................................ ................................ ................................ ................................ ...........................  8 
Bibliography  ................................ ................................ ................................ ................................ ........................  9 
 
 DUS 1659: 2022  
iv © UNBS 2022 – All rights reserved  
 Foreword  
Uganda National Bureau of Standards (UNBS) is a parastatal under the Ministry of Trade , Industry and 
Cooperatives established  under Cap 327 , of the Laws of Uganda , as amended .  UNBS is mandated to co -
ordinate the elaboration of standards and is  
(a) a member of International Organisation for Standardisation (ISO) and  
(b) a contact point for the WHO/FAO Codex Alimentarius Commission on Food Standards, and  
(c) the National Enquiry Point on TBT  Agreement  of the World Trade Organisation (WTO).  
The work of preparing Uganda Standards is carried out through Technical Committees. A Technical 
Committee is established to deliberate on standards in a  given field or area and consists of key stakeholders 
including government, academia, consumer groups, private sector and other interested parties.  
Draft Uganda Standards adopted by the Technical Committee are widely circulated to stakeholders and the 
general public for comments. The committee reviews the comments before recommending the draft standards 
for approval and declaration as Uganda Standards by the National Standards Council.  
The committee responsible for this document is Technical Committee UNBS /TC 201, Food Packaging, 
Handling and Materials  in contact with food . 
This second edition cancels and replaces the first edition ( US 1659 :2017 ), which has been technically revised.  
 
 UGANDA STANDARD  DUS 1659: 2 022 
 
© UNBS 2022 – All rights reserved  1 
 Materials and articles in contact with food — Requirements  for 
material s and surfaces   
1 Scope   
This Draft Uganda  Standard provides requirements, sampling and test methods for food contact surfaces 
including packaging materials that are intended for that purpose and can be expected  to come into contact 
with food under normal or foreseeable conditions o f use.  
The standard does not include coverings or coatings and substances that are part of the food and may be 
eaten with it such as sausage skin for which other standards apply . 
2 Normative references   
The following referenced d ocuments referred to in the text in such a way that some or all of their content 
constitutes requirements of this document. For dated references, only the edition cited applies. For undated 
references, the latest edition of the referenced document (includi ng any amendments) applies.  
ISO 4531, Vitreous and porcelain enamels — Migration from enamelled ware in contact with food — Method 
of test and permissible limit.  
ISO 6486 -1; Ceramic ware, glass -ceramic ware and glass dinnerware in contact with food -- Release of lead 
and cadmium -- Part 1: Test method  
ISO 7086 -1, Glass hollowware in contact with food — Release of lead and cadmium — Part 1: Test method  
ISO/TS 22002 -4, Prerequisite programs on food safety —Part 4: Food packaging manufacturing  
US 1675, Det ermination of overall migration of constituents of plastic materials and articles intended to come 
in contact with foodstuffs — method of analysis  
US 45 , General  standard for food additives  
3 Terms and definitions   
For the purposes of this document, the fo llowing terms and definitions apply.  
ISO and IEC maintain terminological databases for use in standardization at the following addresses:  
— ISO Online browsing platform: available at http://www.iso.org/obp  
3.1  
additive  
substance such as hardener, plast icizer  and preservative  added to a base material to achieve a specific 
property   
2 © UNBS 2022  – All rights reserved  
 3.2  
contamination  
all possible pollution of the finished packaging material  or article , including microbiological, chemical and 
physical contaminants not intentionally adde d to the product and may compromise food safety  
3.3  
rework material  
reuse of internal scrap of certain production into material with the same composition  
3.4  
food packaging  
any product to be used for containment, protection, handling, delivery, storag e, transport and presentation of 
food  
3.5  
migration  
transfer of substances from an external source to food  
 
3.6  
active materials and articles  
materials and articles that are intended to extend the shelf -life or to maintain or improve the condition of 
packaged food; they are designed to deliberately incorporate components that would release or absorb 
substances into or from the packaged food or the environment surrounding the food  
3.7  
intelligent materials and articles  
materials and articles which mo nitor the condition of packaged food or the environment surrounding the food  
3.8  
leaching  
process of extracting substances from a solid by dissolving them in a liquid  
3.9  
food grade contact  material  
material which does not contaminate food with harm ful substances on coming in contact with it  
3.10  
resin  
solid or highly viscous substance, typically convertible into polymers  
3.11  
material safety data sheet  
document that contains information on the potential hazards and how to work safely with a gi ven chemical 
product  
3.12  
colourant  
ingredient that alone or in combination with other ingredients impart or change the colour of the product  
3.13  
certificates of analysis  
documents that confirms conformance to specifications or regulations  
3.14  
food  
any substance or product, whether processed, partially processed or unprocessed, intended to be, or 
reasonably expected to be ingested by humans. It includes drink, chewing gum and any substance, including 
water, intentionally incorporated into the food  during its manufacture, preparation or treatment.  DUS 1659: 2022  
© UNBS 2022  – All rights reserved  3 
 3.15  
good manufacturing practices.  
those aspects of quality assurance which ensure that materials and articles are consistently produced and 
controlled to ensure conformity with the rules applicable to t hem and with the quality standards appropriate to 
their intended use by not endangering human health or causing an unacceptable change in the composition of 
the food or causing a deterioration in the organoleptic characteristics thereof.  
3.16  
non-food -contact side  
surface of the material or article that is not directly in contact with food.  
3.17  
food -contact side  
surface of a material or article that is directly in contact with the food.  
3.18  
recycle d materials  
material that has been reprocessed from recovered [reclaimed] material by means. of a manufacturing 
process and made into a final product or into a component for incorporation into a. final product  
4 Requirements  
4.1  General  
The kind of food contact surfaces  and the materials including active m aterials and intelligent materials used 
shall be  manufactured in accordance to Good manufacturing practices and shall be in such a way that :  
a) the material or article  itself does not have an adverse effect on the food product (for example, through 
chemical reactions, leaching of  materials or absorption ;  
b) the food product does not have an adverse effect on the packaging  material , changing its properties 
or affecting its protective function;  
c) it does not result into unacceptable changes in the organoleptic ch aracteristics of the food  and 
d) it is strong enough to hold the contents when subjected to normal handling  
4.2 Raw materials  
4.2.1 General  
Raw materials used in the manufacture o f items for food   contact use shall be food grade contact  and shall be 
accomp anied with relevant certificates of analysis and material safety data sheets.  
4.2.2 Identification of raw materials  
The manufacturer shall ensure that the raw materials are of the correct food grade and are correctly labelled  
for food contact use. R aw ma terials identified as prescribed shall be accepted only in clean, tamper proof 
containers.  
4.2.3 Colourants  
Colourants used in materials including packaging materials which are to come into contact with food shall be 
food grade contact.   
4 © UNBS 2022  – All rights reserved  
 4.2.4 Rework mat erials  
Rework materials used  in the manufacture of  items for food contact use shall be prepared from raw items that 
have not been used or printed and have been manufactured in compliance with Good Manufacturing 
Practices.  
4.2.5  Recycles materials  
Post-consumer recycled materials shall be assessed and declared suitable and safe for use in direct contact 
with food.  
4.2.5 Resins  
The resins selected shall be of food grade contact material.  
4.3 Storage and control  
Packaging materials and rework materials i ntended for food contact use shall be stored separately from other 
materials in closed, properly identified containers.  
4.4 Additives, processing aids and colorants  
The additives, processing aids and colorants selected and their dosages should be of food  contact grade 
according their prescribed conditions of use.  
4.5 Printing ink s and coating s  
4.5.1  Printing inks and or coatings for food contact use  shall comply with the general requirements given in 
4.1 of this standard and shall be of food  contact  grade.  
4.5.2  Printing inks applied to the non food -contact side of materials and articles shall be formulated and/or 
applied in such a manner that substances from the printed surface are not transferred to the food -contact side:  
(a) through the substrate or;  
(b) by set -off in the stack or the reel, in concentrations that lead to levels of the substance in the food which 
are not in line with the requirements of this standard.  
4.5.3  Printed materials and articles shall be handled and stored in their finished an d semi -finished states in 
such a manner that substances from the printed surface are not transferred to the food -contact side  
4.5.4  The printed surfaces shall not come into direct contact with food.  
4.6 Performance of  materials  and articles   
4.6.1  The perf ormance of the  material shall be identified clearly during the manufacturing and the following 
shall at least be considered:  
a) nature of  the food product to be contained ;  
b) surface/volume ratio;  
c) expected maximum shelf -life of the food product;  
d) filling, sealing and storage methods to be used; and  
e) heating, cooling, sterilization and pasteurization pr ocesses to which the  material and contents may be 
exposed.  
 DUS 1659: 2022  
© UNBS 2022  – All rights reserved  5 
 4.6.2  The required performance shall, wherever possible, be translated into technical  specifications such 
as permeability, mechanical strength, barrier properties and specific organoleptic tests to be performed  
4.7 Migration  
4.7.1 General  
Materials  and articles  for food contact use shall not transfer their constituents to foodstuffs in  quantities 
exceeding specific migration limits and/or overall migration l imits when tested according to relevant standards.  
This shall be attained by either:  
a) obtaining and verifying information received from supplier about the compliance with specific restrictions;  
b) controlling or verifying the composition of the raw materials;  
c) controlling or verifying the migration features of the raw materials;  
d) use of functional barriers; or  
e) testing directly the intermediate or finished products.  
Where  migration analysis is not considered necessary and thus not conducted, a justification shall be 
provided.  
4.7.2  Plastic materials  
Plastic containers  intended to come into contact with food when sampled and tested according to US 1675 
shall not exceed 6 0 mg of the constituents released per kilogram of foodstuff or food simulant (mg/kg) (overall 
migration limit). However, this limit shall be 10 mg/dm2 of surface area of material or article in the case of the 
following:  
a) articles which are containers or  are comparable to containers or which can be filled, with a capacity of less 
than 500 ml or more than 10 l; and  
b) sheet, film or other material or articles which cannot be filled or for which it is impracticable to estimate the 
relationship between the surface area of such material or article and the quantity of food in contact therewith.  
4.7.3  Food contact materials made of metals and alloys  
4.7.3 .1 Alloys  for food contact shall contain only aluminium, chromium, copper, gold, iron, magnesium, 
mangane se, molybdenum, nickel, silicone, silver, tin titanium, zinc, cobalt, vanadium and carbon. aluminium, 
antimony, arsenic, barium, beryllium, cadmium, chromium,  
4.7.3 .2 Release  of heavy metals from metals and alloys for food contact purposes shall not exceed  those 
specified in table 1   
6 © UNBS 2022  – All rights reserved  
 Table 1. Maximum  release limits  for heavy metals in metals and alloys for food contact use  
Heavy metal  Maximum limit mg/Kg  Test method  
Aluminium  5 DUS ISO 16918  
Antimony  0.04 
Arsenic  0.002  
Barium  1.2 
Beryllium  0.01 
Cadmium  0.005  
Chromium  0.250  
Cobalt  0.02 
Iron  40 
Lead  0.010  
Lithium  0.048  
Manganese  1.8 
Mercury  0.003  
Molybdenum  0.12 
Nickel  0.14 
Silver  0.08 
Thallium  0.0001  
Tin  100 
Vanadium  0.01 
Zinc  5 
 
4.7.4  Glass contai ners   
Permissible limits shall be 0.5 mg/kg for lead and 0.25 mg/kg for cadmium when tested according to ISO 
7086 -1. 
4.7.5   Ceramic packaging materials  
Quantities of lead and cadmium transferred from ceramics when tested according to US ISO 6486 -1shall no t 
exceed the limits given in Table 1.  DUS 1659: 2022  
© UNBS 2022  – All rights reserved  7 
 Table 1 — Permissible limits for lead and cadmium for ceramic items intended to come into contact 
with food  
Category  Description  Maximum permissible limits  Test method  
Lead  Cadmium  
1 Items which cannot be filled 
and items which can be filled, 
the internal depth of which 
measured from the lowest 
point to the horizontal plane 
passing through the upper rim 
does not exceed 25 mm. 
mg/dm2  0.8 0.07 ISO 6486 -1 
2 All other items which can be 
filled, mg/l  4.0 0.3 
3 Items having a capacity of 
more than 3 l, mg/l  1.5 0.1 
 
4.7.6  Active and intelligent food contact materials and articles  
4.7.6.1  Active and intelligent food contact materials and articles should  not change the composition or the 
organoleptic properties of food  or give information about the condition of the food that could mislead 
consumers.  
4.7.6.2  Active  food contact materials and articles which produce colour changes to the food that give the 
wrong information concerning the condition of the food could mislea d the consumer and therefore shall  not be 
allowed either.  
4.7.6.3  Intelligent materials and articles shall not give information about the condition of the food which could 
mislead consumers  
4.7.6.4  Active food contact materials and articles that may change  the composition or the organoleptic 
properties of the food shall comply with the requirements of US 45.  
4.7.7 Non-regulated substances  
4.7.6.1  In instances where substances used in raw materials for packaging may not be covered by any of 
the available le gislation, guidelines or recommendations, confirmation shall be obtained from the suppliers 
that they have identified and made a safety assessment of the non -regulated substances, in order to avoid the 
exposure of consumers to migrating substances at level s that could potentially pose a risk to consumer health .  
5  Hygiene  
Food grade contact  packaging materials shall be produced and handled in hygienic manner in accordance 
with US ISO TS 22002 -4 to prevent contamination putting into consideration that mos t packaging items may 
not be sterilized before use.   
8 © UNBS 2022  – All rights reserved  
 6 Packaging  
Packaging items for food contact shall be packaged in such a manner as to ensure that the items do not 
become contaminated during handling and storage .  
7 Weights and measures  
The weight of  the package of the product shall comply with the Weights and Measures Act.  
8 Labelling  
8.1 The following specific requirements shall apply and shall be legibly and indelibly marked on each 
consignment and or packing slips:  
a) name of the packaging mate rial;  
b) name and physical address of manufacturer and/or distributor;  
c) type of food suitable for the packaging;  
d) temperature at which the food should be packaged;  
e) net weight or length in metric units;  
f) lot identification (batch number);  
g) storage conditions; and  
h) the words “ for food contact use” or the following symbol shall appear on the labelling.  
 
8.2 When labelling non -retail packages, information for non -retail packages shall either be given on the 
packages or in accompanying doc uments, except that the name of the produce, lot identification and the 
name and address of the manufacturer or packer shall appear on the package.  
8.3 Active and intelligent materials and articles already brought into contact with food shall be adequately  
labelled to allow identification by the consumer of non -edible parts.  
8.4 Active and intelligent materials and articles shall be adequately labelled to indicate that the materials or 
articles are active and/or intelligent.   DUS 1659: 2022  
© UNBS 2022  – All rights reserved  9 
 Bibliography  
[1 [1] Regulation (EC) No 1935/2004 – Materials and Articles in Contact with Food .  
[2] CFR 21 - Code of Federal Regulations Title 21   
[3] US 1659:2017  Materials  in contact with food - Requirements for packaging materials  
 DUS 1659: 2022  
© UNBS 2022 – All rights reserved  11 
 Certification marking  
Products that conform to Ug anda standards may be marked with Uganda National Bureau of Standards 
(UNBS) Certification Mark shown in the figure below.  
The use of the UNBS Certification Mark is governed by the Standards Act, and the Regulations made 
thereunder. This mark can be used only by those licensed under the certification mark scheme operated by 
the Uganda National Bureau of Standards and in conjunction with the relevant Uganda Standard. The 
presence of this mark on a product or in relation to a product is an assurance that the  goods comply with the 
requirements of that standard under a system of supervision, control and testing in accordance with the 
certification mark scheme of the Uganda National Bureau of Standards. UNBS marked products are 
continually checked by UNBS for co nformity to that standard.  
Further particulars of the terms and conditions of licensing may be obtained from the Director, Uganda 
National Bureau of Standards.  
 
 DUS 1659: 2022    
 
ICS ICS 67 .250 
Price based on nn pages  
© UNBS 2022 – All rights reserved