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Regulation of Food Contact Materials in the GCC Member States*

December 9, 2019

The regulation of food contact materials in the Member States of the Cooperation Council for the Arab States of the Gulf – also known as the Gulf Cooperation Council and hereafter referred to as the GCC – is characterized by consensus-based standards established by the GCC Standardization Organization (GSO). The GSO standards set forth general conditions and specific compositional requirements for various types of food contact materials. In large part, the requirements of these standards mirror the European Union’s (EU) regulations on food contact materials.[1] Following a global trend, a number of GCC member states have recently imposed new restrictions on plastic bags and other single-use plastic articles, which impact plastic food contact materials.

Background on the GCC

The GCC was established in 1981 as a strategic union of the United Arab Emirates (UAE), the Kingdom of Bahrain, the Kingdom of Saudi Arabia, the Sultanate of Oman, the State of Qatar, and the State of Kuwait. It is headquartered in Riyadh, Saudi Arabia.  Joint defense and security were major drivers of the creation of the GCC, but free trade between the Member States is another significant purpose of the GCC. The basic objectives of the GCC described in its Charter include coordination and unity between the Member States, stimulating scientific and technological progress in a number of fields, and establishing common regulations in a variety of areas.[2]

The primary working units of the GCC are the Supreme Council, the Ministerial Council, and the Secretariat General.[3] The Supreme Council, made up of the heads of the Member States, is the highest authority of the GCC. It sets high-level policies for the GCC and appoints the Secretary-General and reviews the reports of the Ministerial Council, among other tasks.[4] The Ministerial Council proposes policies and recommendations to develop cooperation between the Member States, and reviews matters referred to it by the Supreme Council.[5] The Secretariat General organization houses the Secretary-General of the GCC as well as assistants and staff. The Secretariat General’s work includes preparing studies and reports in furtherance and related to the goals of the GCC.[6]

Background on the GSO

With the purpose of unifying standards activities in accord with best international practices, the GCC Standardization Organization (GSO) develops consensus-based standards for its members.[7] The following entities are GSO members, which include the standards bodies of the GCC Member States and Yemen:

  • Emirates Authority for Standardization & Metrology (ESMA)
  • Bahrain Standards & Metrology Directorate (BSMD)
  • Saudi Standards, Metrology and Quality Organization (SASO)
  • Directorate General for Specifications and Measurements (DGSM) (Oman)
  • Qatar General Organization for Standardization (QS)
  • Standards and Industrial Services Affairs – KOWSMD (Kuwait)
  • Yemen Standardization, Metrology and Quality Control Organization (YSMO)

The General-Secretariat – headed by the Secretary-General – manages the affairs of the GSO, and presides over the other GSO departments, including the Corporate Services, Outreach, Conformity, Standards & Metrology, and Technology Departments.[8] The GSO has signed Memoranda of Understanding (MOU) with international organizations, such as the International Organization for Standardization (ISO), regional organizations, such as the European Committee for Standardization (CEN), and national organizations, such as the American National Standards Institute (ANSI).[9] The MOUs are intended to strengthen coordination with outside organizations, and help GSO avoid duplication of efforts in the standard setting process.[10]

GSO standards are established by its various Technical Committees comprising representatives from the GSO and each GSO member (i.e., the national standards bodies). Other public and private stakeholders may participate in the standards development process through the national standards bodies.  Some of the GSO standards are drafted by the technical committees; others are adopted (or adapted) from other standard-setting bodies (e.g., ISO, CEN, or International Electrotechnical Commission (IEC) standards). 

While the GSO has developed thousands of standards spanning a wide range of subject areas, the implementation of standards is voluntary in the GCC Member States. The standards must be adopted into national law to have legal effect in the Member States and Yemen. On the other hand, GSO Technical Regulations, which address certain “high priority” product categories in the consumer product realm, have effect unless there are special requirements in the laws and legislation of the Member States regulating the safety of certain products and performing the same purpose.[11]

The GSO’s strategic outcome goals include facilitating trade between Member States, supporting penetration into the global market, developing small and medium scale industries, and assuring customer safety.[12] These goals are reflected in the standards it has developed for food contact materials as discussed below.

GSO Standards on Food Contact Materials

The overarching GSO standards for food packaging include the following:

  • GSO 2231/2012 (“General requirements for materials intended to come into contact with food”)
  • GSO 839/1997 (“Food packages – Part 1: General requirements”)

GSO 2231/2012 is a Technical Regulation that applies to materials and articles that contact, are intended to contact, or are reasonably expected to contact food.[13] This includes active and intelligent (A/I) food-contact materials and articles,[14] but excludes antiques, coverings and coatings that are part of the food and may be consumed with food (e.g., cheese rinds), and water supply equipment.[15] The most significant aspect of GSO 2231/2012 is the general requirement that food contact materials and articles must be manufactured using good manufacturing practice so that – under normal and foreseeable conditions of use – they do not transfer their constituents to food in quantities that could (1) endanger human health, (2) unacceptably change the composition of food, or (3) adversely impact the organoleptic characteristics of food.[16] These requirements are features of numerous food contact material regulatory schemes around the world.[17]

Specific to active and intelligent packaging materials, GSO 2231/2012 specifies that they must be labeled as such, and may not mask food spoilage or otherwise mislead consumers about the packaged food.[18]  

With regard to labeling, GSO 2231/2012 mandates that food contact materials and articles that are placed on the market without food contain the words “for food contact” and bear the internationally used fork and glass symbol .[19] The standard also requires food contact materials and articles to be traceable at all stages to permit the recall of defective products, and allow consumers to identify the manufacturers responsible for the materials and articles.[20] Moreover, business operators must have systems in place to trace materials and articles in the supply chain.[21]

Finally, GSO 2231/2012 includes a list of materials (e.g., adhesives, rubbers, glass, plastics, paper and board) that may be covered by specific measures at the GSO or national level. The standard notes that the specific measures may address the composition, purity, use conditions, and migration limits for these various materials.[22]

Under GSO 839/1997, which also was issued as a Technical Regulation, “packages of food materials” are defined as “containers made from packaging materials suitable for foods and used for their containment, protection, and ease of use, such as metal cans, glass or plastic bottles, tins, paper, plastic and textile bags, wood and plastic boxes, paperboard containers, or any other types of containers including primary and secondary packages.”[23] The standard also defines primary and secondary packaging.[24]  GSO 839/1997 states that materials used in fabricating, forming, or treating packages for food must be “food grade,” defined as a material that does not cause any hazards or health problems, and must be clean so as to avoid contamination of food.[25]

GSO 839/1997 sets forth a number of performance requirements for materials used for food packaging materials. These include the requirements to protect food from acquiring off-odors, flavors, and tastes;[26] to be impermeable to moisture, light and oxygen, as needed;[27] to protect against mechanical hazards such as vibrations;[28] and to consider certain factors in designing food packaging (e.g., ease of opening and closing, ease of transport, and potential for consumer deception).[29]

We next turn to material-specific GSO standards for food contact materials.  GSO 1863/2013 (“Food Packages – Part 2: Plastic Packages – General Requirements”) is a Technical Regulation specific to plastic food packaging, and is the most comprehensive of the material-specific GSO standards that impact food contact materials. “Plastic materials” are defined in GSO 1863/2013 as “materials manufactured from simple petrochemical products of low molecular weights by polymerization to produce high molecular weight compounds such as polyethylene, polypropylene, polyvinyl chloride, polystyrene, and polyethylene terephthalate.”[30] “Plastic package” is defined to include a variety of rigid and flexible plastics articles of varying shapes.[31]

GSO 1863/2013 includes the requirement that plastic raw materials must be of known origin and composition, and must be clean and homogenous and free of foreign materials.[32] As with the other food contact standards discussed above, GSO 1863/2013 states that plastic packaging must not cause consumer health hazards, and must not adversely impact food.[33] Performance requirements akin to those in GSO 839/1997, as well as plastic-specific performance requirements, are found in GSO 1863/2013. For example, creep value must be low to avoid problems due to stacking/handling.[34]

The GSO 1863/2013 standard includes that pigments and colorants used in plastic packages must be nonpoisonous and must not react or mix with food.[35] Likewise, plastic packages must not react with organic solvents or oils in packaged foods, and they must be suitably resistant to acids and bases relative to the food that will be packaged.[36] In terms of labeling, GSO 1863/2013 reiterates the requirement found in GSO 2231/2012 that packages sold without food must bear the glass and fork symbol.[37] 

GSO 1863/2013 establishes an overall migration limit for plastic food contact materials of less than 10 mg/dm2 or 60 mg/kg,[38] and also contains specifications on residual vinyl chloride, styrene, and acrylonitrile in plastic materials.[39] Moreover, GSO 1863/2013 sets forth a positive list of starting substances, macromolecules obtained from microbial fermentation, additives, and polymer production aids (PPA) that may be used in the manufacture of plastic packages. GSO 1863/2013 largely mirrors Regulation (EU) 10/2011 (the EU Plastics Regulation), and Table 1 of the GSO standard includes the first 885 substances found in the EU Plastics Regulation.  As with the EU Plastics Regulation, the substances included in Table 1 are listed by chemical name and CAS Reg. No., as well as unique substance numbers. Table 1 notes whether any specific migration limits (SML) or group SML (SML(T)), or any other restrictions, apply to the use of the listed substances.

Other notable GSO standards for food contact materials include GSO 1193/2002 (“Polyethylene Bags for packaging applications”), which establishes requirements for polyethylene bags used to package food.  The standard requires the use of food grade materials of known origin and composition, and prohibits the use of recycled materials in these polyethylene food bags.[40] The standard also establishes a number of performance specifications. For example, it has requirements on tensile strength and elongation at break. Similarly, GSO 1830/2010, pertaining to woven propylene sacks used in packing agricultural products, establishes performance testing requirements, such as thread count and tensile strength specifications.[41] It also states that the sack fabric must not contain materials that are likely to adversely affect food.[42] GSO 462/1994 (“Single-use rigid and semi-rigid plastic cups and containers for packaging beverages, milk products, and allied purposes”) states that plastic cups and beverage containers must not be hazardous or adversely impact health.[43] In terms of technical characteristics, they must be homogenous in color[44] and they must retain their shape or dimensions under a range of temperature conditions.[45] 

While there is no overarching compositional standard on paper that comes into contact with food, as exists for plastic food contact materials, there are GSO standards on specific applications involving the contact of paper with food. For one, GSO 458/1994 (“Wrapping Paper and Paper Bags”) addresses paper bags used to package food stuff. In addition, GSO 1102/1998 (“Milk Paperboard Containers”) prescribes requirements for disposable pasteurized milk containers manufactured from two-sided, polyethylene-coated paperboard blanks or rolls. This standard requires the use of virgin wood pulp and other “food quality” materials in the manufacture of milk paperboard containers.[46] Moreover, under the standard, ink used for printing milk containers must be free from toxic metals such as lead and chromium, and may not migrate into the packaged product.[47] The standard sets forth specific values for container characteristics, including grammage, thickness, and stiffness.[48] GSO 1102/1998 also includes sampling, testing, packaging, and marking requirements, and each consignment of milk paperboard must be accompanied by a certificate stating its compliance with the standard.[49]

There are numerous other material-specific GSO standards that impact food contact materials including, for example, aluminum foil,[50] cans used for canning food,[51] ceramic cookware,[52] and food service items.[53] The standards can be located on the GSO website where they are organized by mode of implementation (standard or technical regulation) and field of application (e.g., food and agriculture sector, oil and gas sector).

Amending and Adopting GSO Standards

There is no formal process for amending the GSO Standards, but a request to amend a standard can be submitted to the GSO technical committee for review and consideration. Updates are made at the discretion of the GSO. To add a new substance to GSO 1863/2013, for example, information is needed on the identity and intended use of the substance, its migration to food, its toxicology profile, and its regulatory status in other jurisdictions. 

Once a GSO standard has been adopted at the GSO level, the GCC Member States are bound to implement the standards as national standards or national technical regulations. However, in practice, the route to achieving implementation of GSO standards is different in each country.  Saudi Arabia and UAE are known to actively adopt GSO standards by issuing resolutions regarding the standards. On the other hand, while Oman acknowledges that it applies the GSO standards, it does not commonly issue a resolution or decree confirming adoption of the GSO standards. Moreover, timelines for adopting GSO standards vary considerably from country-to-country. Seeking to assure that a food contact material is approved in each GSO member country typically entails a company approaching each national body for confirmation.

With respect to the overarching food contact standards, every GCC Member State has formally adopted GSO 1863/2013 on plastic food contact materials. Moreover, Bahrain has formally adopted GSO 839/1997 and 2231/2012 through the National Committee for Standards and Metrology at the Ministry of Industry, Commerce and Tourism. Bahrain’s Legislative Decree No. 3 of 1985 on the control of imported foodstuffs requires imported food to comply with regulations and rules implemented at the national level. The Decree also prescribes enforcement mechanisms, including inspection and analysis of food samples.[54]

In Kuwait, the Kuwait Public Authority for Industry, Kuwait Municipality, the General Customs Authority, and the Environmental Protection Authority have responsibility for food contact materials. Kuwait’s Ministerial Decision No. 131/2012 sets labeling requirements and imposes civil monetary penalties for selling food packaging that contains substances deemed to be harmful to human health. Decision No. 131/2012 also establishes the authority of government officials to inspect food items and provides detailed requirements for the sampling and analysis of food products.[55]

In Oman, the national standards body is the Directorate General for Specifications and Measurements (DGSM) within the Ministry of Commerce and Industry. Food inspections are handled at the municipal level.  Such inspections include random evaluations of food products in wholesale and retail markets.[56]

Qatar also has formally adopted GSO 839/1997 and 2231/2012 via its General Authority for Standardization and Metrology, which is the national standards body in Qatar. Food safety is addressed in Qatar through various government ministries including the Ministry of Municipality and Environment and the Ministry of Public Health. Enforcement and inspection of food products are currently handled at the municipal level and may include visual inspection and laboratory analysis, particularly to ensure consistency between food labels and food contents.[57]

Saudi Arabia has formally adopted GSO 839/1997 and 2231/2012, and food contact materials fall under the authority of the Saudi Food and Drug Authority (SFDA). SFDA also is responsible for enforcing the GSO and Saudi standards for these materials. The SDFA Executive Department of Imported Food Control (EDIFC) administers random sampling of imported food consignments and may conduct a documentation check, identity check, physical examination, and laboratory testing to determine compliance.[58] Products that are deemed to be non-compliant must be re-exported or destroyed.[59]

UAE has also formally adopted GSO 839/1997 and 2231/2012 through the Emirates Authority for Standardization and Metrology (ESMA). Food contact materials must be manufactured in compliance with good manufacturing practice or other quality schemes adopted by ESMA.  Moreover, the Abu Dhabi Food Control Authority and Dubai Municipality administer their own, specific import requirements.[60] In the UAE, food inspections are handled at the municipal level.[61] Inspectors randomly evaluate food products in wholesale and retail markets, which can include a visual inspection and laboratory analysis to determine discrepancies between the label and the product’s actual contents.

Environmental Regulations Impacting Food Packaging

In response to growing concerns about the presence of plastic in the environment, several GCC Member States have enacted environmentally-focused restrictions and regulations on plastic that impact food contact materials. Other GCC Member States have indicated that they will take similar action in the future.

In 2016, the Saudi Standards, Metrology, and Quality Organization (SASO) established technical regulation M.A-156-16-03-03 (“Degradable Plastic Products”), a three-phase ban on disposable plastic products made of polypropylene and polyethylene. The regulation applies to packaging materials and products that are imported, as well as those that are manufactured domestically.[62]  Phase I began in July, 2017, and phases II and III – which cover single-use plastic bags and disposable tableware (e.g., plates, spoons, cups) – took effect September 2019.[63] Notably, SASO has indicated that primary food packing is exempt, while secondary packaging for food products, such as plastic covers, cling wrap, plastic liners for cardboard boxes, and heat-shrinkable wrap fall under the regulation.[64] The regulation requires plastic bags, cutlery, and films made of polyethylene and polypropylene up to 250 µm thickness to be oxo-degradable and then biodegradable. 

SASO has established a number of requirements to support licensing of the OXO logo, including among others (1) official registration with SASO, (2) an effective Environment Management System (e.g., ISO 14001), and (3) laboratory testing showing compliance with the M.A-156-16-03-03 standard.[65] A separate application must be submitted for each product intended to be licensed.[66] In 2017, SASO announced that, in cooperation with other governmental bodies, it would begin its enforcement of the Technical Regulation No. (M.A-156-16-03-03) on degradable plastic products, and would prevent import of and manufacture of plastic products in violation of the regulation.

In 2012, the UAE Ministry of Environment and Water implemented a ban on plastic packaging and disposable items, including semi-rigid plastic packaging for food, except oxo-biodegradable plastic that complies with the UAE “Standards & Specification for Oxo-biodegradation of Plastic bags and other disposable plastic” (Standard 5009/2009) that is registered in accordance with the Emirates Conformity Assessment System (ECAS).[67] The ban took effect at the start of 2013.

The most recent of the plastic bans was implemented in Bahrain. Effective on July 21, 2019, Ministerial Order Number (11) for the year 2019 regulates and phases out the use of certain plastics, beginning with single-use plastic bags.[68] The first phase under the Order bans the import of non-biodegradable single-use plastic bags. Later phases under the Order will entail a permanent ban on the use of plastic bags at certain types of retailers. The plastic bag ban was preceded by a market study on the availability of degradable plastic, as well as study of the consumption of biodegradable and compostable plastic in Bahrain.[69]

In Oman, the Ministry of Environment and Climate Affairs (MECA) reported in July 2018 that it had drafted regulations on the use of plastic bags that are awaiting technical amendments from the Ministry of Commerce and Industry.[70] The ban pertains to the use of plastic bags in malls and supermarkets.  The MECA conducted an online survey to determine whether there was public agreement with a plastic bag ban.[71] They reported 88% agreement with the legislation, and they also received numerous suggestions from the public regarding the recycling of plastic bags.[72]

Though Qatar has yet to implement a formal ban on plastic products, the Ministry of Municipality and Environment has expressed its intention to reduce plastic waste to meet the United Nations Sustainable Development Goals for 2030.[73] Likewise, while the Kuwait Environment Public Authority (EPA) announced a gradual shift in 2012 to using paper and biodegradable shopping bags and has gone as far as to commit to a plastic-free Kuwait by the year 2020, Kuwait has yet to implement a formal ban on plastic products.[74] Nevertheless, there is a growing trend in the Middle East and elsewhere to eliminate certain single-use plastics, including plastic grocery bags and disposable food service ware. 

Conclusion

The compositional and performance requirements for food contact materials in the GCC Member States are characterized by various GSO technical regulations. All food contact materials marketed in the GCC Member States are required to be safe for the intended use, and may not affect the organoleptic properties of food. Plastic food contact materials are subject to the most extensive of the GSO technical regulations, GSO 1863/2013, which sets forth a positive list of starting materials and additives. Recently, one of the primary issues facing food contact material manufacturers and importers in the Middle East is the bans on single-use plastics that impact plastic food contact materials. Through these bans, there is an ongoing shift toward the use of biodegradable plastics in numerous food contact applications.

 

* This article is reprinted with the permission of Elsevier. It was first published in Elsevier’s Reference Module in Food Science.

 

[1]           Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food.

[2]           Article 4 of the GCC Charter, available at https://www.gcc-sg.org/en-us/AboutGCC/Pages/Primarylaw.aspx.

[3]           Article 6 of the GCC Charter.

[4]           Article 8 of the GCC Charter.

[5]           Article 12 of the GCC Charter.

[6]           Article 15 of the GCC Charter.

[7]           https://www.gso.org.sa/en/about-gso/vision-mission-values/

[8]           https://www.gso.org.sa/en/about-gso/general-secretariat/

[9]           https://www.gso.org.sa/wp-content/uploads/2017/10/List-of-MoUs.pdf

[10]         https://www.gso.org.sa/en/about-gso/gso-international-agreements/

[11]         https://www.gso.org.sa/en/conformity/gcc-conformity-assessment-scheme/

[12]         https://www.gso.org.sa/en/about-gso/gso-strategy-2016-2020/

[13]         GSO 2231/2012, Article 1.

[14]         GSO 2231/2012, Article 3 (3.1).

[15]         GSO 2231/2012, Article 1.

[16]         GSO 2231/2012, Article 3 (3.1, 3.1.1, 3.1.2, and 3.1.3).

[17]         See, e.g., Regulation (EC) No 1935/2004 of the European Parliament and of the Council, Article 3, stating that Materials and articles, including active and intelligent materials and articles, shall be manufactured in compliance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer their constituents to food in quantities which could:  (a) endanger human health; or (b) bring about an unacceptable change in the composition of the food; or (c) bring about a deterioration in the organoleptic characteristics thereof.  See also the U.S. Food and Drug Administration’s Food Additive Regulations at 21 C.F.R. § 174.5 (“General provisions applicable to indirect food additives”), stating that “any substance used as a component of articles that contact food shall be of a purity suitable for its intended use” and confirming the food packaging materials may not impart odor or taste to food.

[18]         GSO 2231/2012, Article 3 (3.5, 3.2, and 3.3).

[19]         GSO 2231/2012, Article 4 (4.1 and 4.8).

[20]         GSO 2231/2012, Article 5 (5.1).

[21]         GSO 2231/2012, Article 5 (5.2 and 5.3).

[22]         GSO 2231/2012, Article 3 (3.6.1).

[23]         GSO 839/1997, Article 3 (3.1).

[24]         Primary packages have interior surfaces that directly contact food, while secondary packages are external packaging for primary packaging materials used to transport, store, distribute, and market packaged food.  GSO 839/1997, Article 3 (3.1 and 3.2).

[25]         GSO 839/1997, Article 4 (4.1 and 4.2), Article 3 (3.4).

[26]         GSO 839/1997, Article 4 (4.3).

[27]         GSO 839/1997, Article 4 (4.5 and 4.6).

[28]         GSO 839/1997, Article 4 (4.8).

[29]         GSO 839/1997, Article 4 (4.9).

[30]         GSO 1863/2013, Article 3 (3.1).

[31]         GSO 1863/2013, Article 3 (3.3).

[32]         GSO 1863/2013, Article 4 (4.1 and 4.2).

[33]         GSO 1863/2013, Article 4 (4.3 and 4.4).

[34]         GSO 1863/2013, Article 4 (4.9).

[35]         GSO 1863/2013, Article 4 (4.5).

[36]         GSO 1863/2013, Article 4 (4.12 and 4.10).

[37]         GSO 1863/2013, Article 8 (8.1).

[38]         GSO 1863/2013, Article 4 (4.21).

[39]         GSO 1863/2012, Article 4 (4.17, 4.18, and 4.19).

[40]         GSO 1193/2002, Article 5 (5.1.3).

[41]         GSO 1830/2010, Article 4 (4.7).

[42]         GSO 1830/2010, Article 4 (4.2).

[43]         GSO 462/1994, Article 3 (3.3).

[44]         GSO 462/1994, Article 3 (3.2).

[45]         GSO 462/1994, Article 3 (3.6).

[46]         GSO 1102/2002, Article 3 (3.2 and 3.1).

[47]         GSO 1102/2002, Article 3 (3.5 and 3.6).

[48]         GSO 1102/2002, Article 3 (3.7).

[49]         GSO 1102/2002, Article 8.

[50]         GSO 2515/2016 (“Food packages made of aluminum foil”).

[51]         GSO 1793/2007 (“Two piece aluminum round cans used for canning food (Beverages & stuff)”); GSO 1794/2007 (“Two piece steel round cans used for canning food-stuffs”).

[52]         These are primarily adoptions of ISO standards, such as GSO ISO 6486-1/2016 (“Ceramic ware, glass-ceramic ware and glass dinnerware in contact with food -- Release of lead and cadmium -- Part 1: Test method”) and GSO ISO 6486-2/2013 (“Ceramic ware, glass-ceramic ware and glass dinnerware in contact with food -- Release of lead and cadmium -- Part 2: Permissible limits”).

[53]         GSO ISO 14285/2015 (“Rubber and plastics gloves for food services -- Limits for extractable substances”).

[54]         See Food and Agriculture Organization of the United Nations, FAOLEX Database: Bahrain (last visited June 20, 2019), http://www.fao.org/faolex/results/details/en/c/LEX-FAOC072231.

[55]         See Food and Agriculture Organization of the United Nations, FAOLEX Database: Kuwait (last visited June 20, 2019), http://www.fao.org/faolex/results/details/en/c/LEX-FAOC183745.

[56]         See Mohamed Taha and Judge Akhidenor, Oman: Food and Agricultural Regulations and Standards – Narrative, Global Agricultural Information Network, USDA Foreign Agricultural Service (Apr. 8, 2012), https://gain.fas.usda.gov/Recent%20GAIN%20Publications/Food%20and%20Agricultural%20Import%20Regulations%20and%20Standards%20-%20Narrative_Dubai_Oman_4-8-2012.pdf.

[57]         Agricultural & Processed Food Products Export Development Authority, Government of India, Doc. Code. QAT1000 (May 20, 2010), http://apeda.in/agriexchange/food_standards/Int_document/QATAR.pdf.

[58]         Alan Hallman and Hussein Mousa, Saudi Arabia: Food and Agricultural Import Regulations and Standards Report, Global Agricultural Information Network, USDA Foreign Agricultural Service at 27-28 (Apr. 7, 2019), https://gain.fas.usda.gov/Recent%20GAIN%20Publications/Food%20and%20Agricultural%20Import%20Regulations%20and%20Standards%20Report_Riyadh_Saudi%20Arabia_4-7-2019.pdf.

[59]         Alan Hallman and Hussein Mousa, Saudi Arabia: Food and Agricultural Import Regulations and Standards Report, Global Agricultural Information Network, USDA Foreign Agricultural Service (Apr. 7, 2019) at 27-28, available at https://gain.fas.usda.gov/Recent%20GAIN%20Publications/Food%20and%20Agricultural%20Import%20Regulations%20and%20Standards%20Report_Riyadh_Saudi%20Arabia_4-7-2019.pdf.

[60]         See Abu Dhabi Food Control Authority, Code of Practice No. (26)/2014: Food Contact Materials (Plastic Food Packaging Materials) (Oct. 28, 2014), https://www.adfca.ae/Documents/cop%20contact%20materials.pdf; see also Government of Dubai, Important Information to Food Traders, dm.gov.ae (last visited June 21, 2019), https://www.dm.gov.ae/en/Business/FoodSafetyDepartment/Pages/default.aspx.

[61]         See Kurt Seifarth and Mohamed Hamza, United Arab Emirates: Food and Agricultural Import Regulations and Standards Report, Global Agricultural Information Network, USDA Foreign Agricultural Service (May 1, 2019), available at https://www.fas.usda.gov/data/united-arab-emirates-fairs-annual-country-report; see also Emirates Authority for Standardization & Metrology, UAE Regulation for Control on Food Contact Material, manaa.esma.gov.ae.

[62]         Silvana Giger, New Regulations for Plastics in Saudi Arabia, Switzerland Global Enterprise (Feb. 7, 2019), available at https://www.s-ge.com/en/article/news/20173-saudi-arabia-clean-plastic-legislation.

[63]         Saudi Standards, Metrology and Quality Organization, Registration of Plastic Products, saso.gov.sa.

[64]         See Annex 1 of M.A-156-16-03-03.  See also Alan Hallman and Hussein Mousa, Saudi Arabia: Food and Agricultural Import Regulations and Standards Report, Global Agricultural Information Network, USDA Foreign Agricultural Service (Apr. 7, 2019), available at https://gain.fas.usda.gov/Recent%20GAIN%20Publications/Food%20and%20Agricultural%20Import%20Regulations%20and%20Standards%20Report_Riyadh_Saudi%20Arabia_4-7-2019.pdf.

[65]         Article 4 of M.A-156-16-03-03. 

[66]         Article 5/1 (A) of M.A-156-16-03-03. 

[67]         See Emirates Conformity Assessment Scheme, Specific Requirements for the Registration of Oxo-Biodegradable Plastic Bags and Other Related Packaging Materials According to UAE Standard 5009:2009, Emirates Authority for Standardization and Metrology (Dec. 13, 2009), available at http://www.lacecot.org/documents/Doc5383.pdf; see also Liz Gyekye, UAE Brings Forward Ban on Disposable Plastics, Packaging News (Feb. 20, 2012), available at https://www.packagingnews.co.uk/news/uae-brings-forward-ban-on-disposable-plastics-20-02-2012 and Samir Salma, UAE Bans Non-biodegradable Plastic Products, https://gulfnews.com/uae/environment/uae-bans-non-biodegradable-plastic-...

[68]         See Manama, The Kingdom of Bahrain to Ban Plastic Bags in July, Bahrain News Agency (June 12, 2019), available at https://www.bna.bh/en/news?cms=q8FmFJgiscL2fwIzON1%2BDl2HBpvwEOCWP28NolWfrjA%3D.

[69]         Plastic bags to be banned in Bahrain by July, Bahrain This Week, (June 13, 2019), available at https://www.bahrainthisweek.com/plastic-bags-to-be-banned-in-bahrain-by-july/.

[70]         Tingmin Koe, Oman the Latest Nation to Announce Ban of Plastic Bag Use in All Supermarkets, Food Navigator Asia (July 4, 2018), available at https://www.foodnavigator-asia.com/Article/2018/07/04/Oman-the-latest-nation-to-announce-the-ban-of-plastic-bag-use-in-all-supermarkets.

[71]         https://meca.gov.om/en/module.php?module=pages-showpage&CatID=57&ID=154.

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