Revision of  Testing Methods for Containers and Packages Intended for Milk and 
Milk Products  
 
 
1. Purpose and background  
 
Containers and packages exclusively intended for milk and milk products  are 
subject to the Ministerial Ordinances concerning Compositional Standards Etc. for 
Milk and Milk Products (Ministry of Health and Welfare Ordinance No. 52, 1951, 
herein after referred to as the “Ministerial Ordinances ”), separately from contain ers 
and packages used for many other purposes.   
 
The current testing methods for containers and packages based on the Ministerial 
Ordinances  have been seldom  modified since the initial establishment of them. 
These methods still contain procedures using ha rmful re agents, such as mercury 
and they do not reflect the recent advanced analytical technology. On the other 
hand, testing methods for containers and packages that are specified in the 
Specifications and Standards for Food, Food Additives, Etc. wer e sub stantially 
improved in 2006 .  
The proposed revision aims to harmonize  with the testing methods in Notification 
No. 370 by keeping up with advanced analytical technology.   
 
 
2. Outline  of revision  
 
1. Modification of testing methods  
 
Some test ing methods will be modified:  
—to replace harmful re agents, such as  mercury and carbon tetrachloride , by less 
harmful ones, and  
—to improve analytical accuracy by introducing methods capable of providing 
higher reproducibility and other advanced methods.  
 
The individual  changes are outlined below  
 
a. Atomic Absorption Spectrophotometry (AAS)  
The use of Electrothermal -AAS will be made possible . Currently, flame -AAS is only 
specified as the official  method. This modification will be applied to all tests using 
AAS as the testing methods for containers and packages specified in the Ministerial Ordinances.   
 
b. Material tests  
Cadmium and lead  
 Polarography will be removed to stop the use of mercury.  
 Inductively Coupled Plasma -Atomic Emission Spectrophometry  (ICP-AES)  will 
be added to enable multiple metals to be determined at a time.  
 Hydrochloric acid treatment will be added to the preparation of the test solution 
to reduce the interference by barium and calcium coexisting in the solution.  
 
Vinyl chloride and volatile  matter  
 The column used for gas c hromatography will be changed from a packed column 
to a capillary column capable of providing higher determination sensitivity and 
separation , in order to improve resolution.   
 
Dibutyl tin compounds  
 The extracting solvent will be changed  from a carbon tetrachloride -methanol 
mixture to an acetone -hexane mixture.  
 The test by paper chromatography will be replaced by the test by GC/MS (gas 
chromatography/mass spectrometry) to heighten separation capabilit y 
 
Cresol ester phosphate   
 The extracting solvent will be changed  from a carbon tetrachloride -methanol 
mixture to acetonitrile .   
 Gas Chromatography will be replaced by Liquid Chromatography to make the 
procedure s easier and to heighten recovery and reprod ucibility.  
 
c. Both material -test and migration -test categories  
Arsenic    
 The current method will be replaced by a new method to avoid using  mercury 
bromide test paper.  
 
d. Migration -test category  
Antimony  
 The current method  will be removed and the use of AAS or  ICP-AES will be 
made p ossible.   
Germanium     
 The current method  will be removed to avoid using  carbon tetrachloride . Instead, the use of AAS or ICP -AES will be made possible.  
 
Phenol  
 The b romine method will be replaced by the 4 -aminoantipyrine method  to 
heighten detection  sensitivity.  
 
2. Indication  of limit values  
 
Limit values will be  given in individual  tests. In some of the current tests, 
including the migration tests for plastics , the determination of conformity with 
specification is conducted by comparing to the standard solutions specified  but the 
corresponding limit s are not given in individual  tests.  The proposed revision  aims to 
let examiners know each specification limit  readily .  (e.g., not more than 0.8 g/ml 
as Pb)  
 
3. Other matters  
 
 Change in units:  ppm → g/ml, g/g  
 Some changes to descriptions  
 
 
3. Date of enforcement  
 
Requirements  shall apply to the products manufactured or imported after the s ix 
months period beginning on the date of promulgation.