How to Export Food Contact Products to Saudi ArabiaPresenter: Kathryn Sharp | Date: March 4, 2021
[email protected]@qima.com
Overview of SASO
Key requirements for exporting products to Saudi Arabia
Key technical requirements and testing standards for food contact products exported to Saudi Arabia
Importer challenges
How QIMA can help
Agenda
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Disclaimer: The information provided in this webinar is an overview. Please refer to the most recent version of the technical regulation and related standards on https://saber.sa/home/regulations when applying for the Food Contact certificate.
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Ensure the smooth entry of goods into the Kingdom of Saudi Arabia
SASO manages the Saudi Product Safety Program called SALEEM to guarantee the safety and quality of products entering Saudi Arabia
All regulated products must be accompanied by a Product Certificate of Conformity (PCoC)
All consignments of goods must also be accompanied by a Shipment Certificate of Conformity (SCoC)
QIMA is fully accredited by SASO to act as a Conformity Assessment Body (CB) to issue Certificates of Conformity for products exported from:
Asia and AustraliaEuropeAmericas (North and South)Middle East and North African countries
The following example is for food contact materials
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Using SABER: Certification requirements for food contact products
Product Registration (HS Code, category),
Risk level classification by system based
on HS code
Regulated ProductObtain Type Approval
Certificate (PCoC)
Shipment Certificate Of Conformity (SCOC)
Ready to Import
Select from registered products
Provide technical documentation (test report for food contact materials, factory audit report, technical description, images, etc.)
Select QIMA (certification body) based on export region
Compliance assessment process is implemented in accordance with Saudi Arabia technical requirements
Technical Regulation of Food Safety in the Tools and Devices Used in the Kitchen (E.M. 171-19-06-04)
Applies to Direct Food Contact items:
Preparation
Serving
Preservation
Objectives:
Establish basic requirements
Safeguard the health of consumers
Prevent food contamination
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Examples of food contact tools and devices
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Plates & beverage containers
Kitchen knives
Bread cutting boards
Cheese cutters
Paper & paperboard for filtering
Peeling machines
Mortar
Casseroles & pots
Tea & coffee sets
Kitchen utensils
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* A full list of applicable standards has been included in the appendix.
Basic requirements for food contact products certification
Demonstrate good manufacturing practices
Products must meet the technical requirements*
Product material shall not contaminate food
Products shall be made of food safe material
Supplier must provide a clear description of all materials
• Must be food safe (if touching food) and conform to standards
• Print location should be kept away from side and surface that touches the food
• Supplier must provide a risk assessment of the list of materials used for coatings, including toxicological assessment
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Supplier must identify the raw material manufacturer
Paint and ink coatings:
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Type 3 certification requirements for Product Certificate of Conformity (PCoC) and Shipment Certificate of Conformity (SCoC) application
Food contact products for export
Factory operating license ✓
Images for each product, must include clear images of product label, barcode, packaging ✓
Technical documents• Test reports (laboratory must obtain approval)• Factory audit report (mandatory requirements from 15 February 2020)• Quality (QMS) certification (ISO 9001) – if applicable• TRA Risk assessment report – if applicable• Product inspection report – if applicable• Corrective measures – if applicable
✓
Product Bill of Materials (BOM), design, dimensions, drawings, specifications and images (if applicable)
✓
Shipment documentation: invoices, packing lists, certificates of origin and bills of lading ✓
Certification requirements
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Test sample selection
Same product type, same material, different design
Same product type, same material, same design, different colors
Same product type, same materials, same design, different sizes
Decal transfer patterns using 4C printing
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Bill of Materials example
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Product name
Product photo
Model number
Intended use
Intended food type
Food contact component(s)
included
Material of each food
contact component
Layout of food contact component
Vacuum Flask
1A2020 Vessel designed to serve both
hot and cold
beverages
Beverages Inside Flask Glass
Rubber Ring Silicone
Lid Screw Black PP
Spout ABS material with solver plating and gold plating
Bill of Materials
Technical requirements for food contact products: metal materials
Material Standards Required test
Metal and alloysCouncil of Europe
Resolution CM/Res(2013)9Extractable Heavy Metal Content in Metals and Alloys (21 HM)
Aluminum and aluminum alloys
EN 601(Casting product)
Chemical composition
EN 602(Wrought product)
Chemical composition
Aluminum (with aluminum content over 99.5%) without
food contact coatingSASO 369
General requirement, chemical composition, mechanical properties, requirement for lid and handle (if any), labeling
Coating (domestic cookware)
European Resolution AP (2004) 1
GSO 2014
Overall Migration for Coating Material*The base under the coating must also meet regulatory requirements
TestMaterial type
Test method
Full test Additional colour
Test MethodMaterial Type
ABS PS SAN AS PVC PE PP PA/ Nylon PC PET Other Plastic Melamine
EU Reg. no. 10/2011:
Overall Migration H H H H H H H H H H H H
Specific Migration of Heavy Metals (HM) H H H H H H H H H H H H
Specific Migration of Primary Aromatic Amines (PAA) M M M M M M M H M M M H
or ISA 177 Specific Migration of Phthalates L L L
Total Phthalate Content L L L L H L L L L M M
Specific Migration of Formaldehyde H H
Specific Migration of Bisphenol A (BPA) L M M
Specific Migration of Acrylonitrile M M M
Specific Migration of Butadiene M
Specific Migration of Styrene L L L L
Specific Migration of Melamine M
Specific Migration of Vinyl Chloride Monomer (VCM) M
Specific Migration of Caprolactam L
EU Reg.1935/2004 Sensory Testing L L L L L L L L L L L L
SASO 671 Tableware made from melamine plastics H
Risk Level: H = High; M = Medium; L = Low
Technical requirements for food contact products: plastic materials
Material Standards Required test Additional shape
Ceramic, glass,
enamelSFDA
GSO-Food Contact Material-Leachable
Lead (Pb) and Cadmium (Cd) (Interior) Based on the differences
between the plates and
tablewareGSO-Food Contact Material-Leachable
Chromium (VI) (Interior)
Technical requirements for food contact products: ceramic, glass and enamel
CategoryLeachable Limits
Lead (Pb) Cadmium (Cd) Chromium VI (Cr)
Category 1 0.7 mg/dm2 0.8 mg/dm2 0.005 mg/dm2
Category 2 0.3 mg/L 4.0 mg/L 0.03 mg/L
Category 3 0.1 mg/L 1.5 mg/L 0.03 mg/L
Category 1 Category 2 Category 3
Technical requirements for food contact products: ceramic, glass and enamel
Non-refillable objects and refillable objects with an internal depth of less than
or equal to 25 mm (measured between the lowest point and horizontal plane
passing through the upper edge)
All other articles which can been filled (no limitation of
capacity)
Cookware (no limitation of capacity), packaging/storage vessels with capacity of more than 3 liters
Examples of standards for specific products
Certain products must also meet other standards in addition to the aforementioned food contact requirements
Pressure cookers –SASO 173
Paper bags –SASO 825
Milk bottles –EN 14350
Paper cups –SASO 2911
Technical requirements for food contact products
Examples of requirements for specific materials
Required Test
Material Type
Paper SiliconWood / Bamboo
Textile
European Resolution AP (2002) 1 – Specific Migration of Cadmium (Cd), Lead (Pb) and Mercury (Hg)
H H M
European Resolution AP (2002) 1 – Pentachlorophenol (PCP) Content
H H M
European Resolution AP (2002) 1 – Extractable Formaldehyde H H M
European Resolution AP (2002) 1 – Colorfastness H
European Resolution AP (2004) 5 – Overall Migration for Silicon
H
Risk Level: H = High; M = Medium; L = Low
Technical requirements for food contact products
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Design and labelling requirements
Labelling Requirements
Labelling must meet standard requirements for each product (list of standards is included in the appendix)
Symbols included to indicate food safety
Labelling should be in Arabic or English and be difficult to remove
Warnings and instructions should be in Arabic, or Arabic and English
Labelling must provide traceability (for example a QR code)
Product claims must be accurate and supported by test results
Country of Origin
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Packaging requirements
Packaging materials that comes into contact with food must meet relevant standards
Ensure that lead and other heavy metals do not exceed permitted levels
Plastic containers must have the recycling symbol
Ensure that packaging of food contact items have a biodegradable plastic logo
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Design and labelling requirements
Products must not be offensive to the Islamic religion. They must not include pork derivatives, images of pigs, pig shapes or crosses
Any images on products or packaging which may be offensive to Islam are prohibited
Logos and symbols All pig shapes Assorted symbols
• Six-pointed star• The emblem of a menorah
surrounded by an olive branch on each side
• Hebrew scripts• Kaaba, Medinah Mosque, or
Mosque of the Rock
• Even a pig’s nose (whether 3D or printed) is not allowed
• Devil shapes• Vendetta mask• Anything subject to restrictions
from religious authorities
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Challenges faced by importers
Does every product variation require its own PCoC?
Fewer PCoC needed
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Testing approach: Grouping
Importer Brand Product typeE.g. cookware,
tableware
Country of Origin (COC)
Grouping by:
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Case study 1: Tableware with printed pattern
20 types of plates…
Same importer
Same manufacturer/factory
Same material
Same brand
Only issue 1 Product Certificate (PCoC)
… BUT they have
Different styles (round, petals, square)
Different pattern
The solution?
Reduced number of tests
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Testing approach: Compliance
By brand By product type, materials
By client’s history of compliance
Risk Assessment by Certified Body:
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Case study 2: Various types of vacuum flask
8 types of vacuum flasks…
Same importer
Same manufacturer/factory
Same brand
Same material
… BUT they have
Different colors
Different styles
1. Select the darkest color and complete a full test.
The solution?
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30 types and plates and bowls:
Same importer
Same manufacturer/factory
Same brand
Same material
Case study 3: Various types of tableware
… BUT they have
Different patterns
Different styles
Only three products must be tested:
① Type 1 plate
+ a Type 2 bowl (no interior pattern)
+ b Type 2 bowl (with interior pattern)
The solution?
[email protected]@qima.com
As a SASO-approved Certification Body (CB) QIMA can:
Perform the conformity assessment and approve PCoC for regulated products on SABERReview shipment detail and approve SCoC on SABER
QIMA can also support the following value-added services:
SABER account management (account registration; registering a product; creating a request for a PCoC)SABER product registration only management (self-declaration or creating a request for a PCoC using a non-QIMA CB)PCoC and SCoC SADAD fee facilitation (helping to settle the SABER system invoices)SABER shipment registration management (creating a request for Shipment CoC or Shipment Exemption Request)
Geographic Scope
QIMA is SASO-approved CB for products exported from:
Asia and AustraliaEuropeNorth & South AmericaMiddle East & North Africa
How QIMA can help
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[email protected]@qima.com
List of Standards for Food Contact Tools and Devices
Standard Title Standard No.
General requirements for materials intended to come into contact with food SFDA.FD GSO 2231
Tableware made from Melamine Plastics SASO 671
Food Packages – Part 1: General Requirements SFDA.FD GSO 839
Standard specification for dedicated LDPE foil for use in food packaging SASO 2845
Food Packages – Part 2: Plastic Packages – General Requirements SFDA.FD GSO 1863
Tea and Herbs Bags SFDA.FD GSO 2138
Rubber and plastic gloves for food services – Limits for extractable substances SASO-ISO-14285
Vitreous and porcelain enamels – Release from enamelled articles in contact with
food – Methods of test and limitsSASO-ISO-4531-1
Vitreous and porcelain enamels – Release of lead and cadmium from enamelled
ware in contact with food – Part 2: Permissible limitsSASO-ISO-4531-2
Wrapping paper and paper bags SASO 825:1994
Single-use, rigid and semi-rigid plastics cups and containers for packing
beverages, milk products and allied purposesSASO 829:1994
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List of Standards for Food Contact Tools and Devices
Standard Title Standard No.
Materials and articles in contact with foodstuffs – Cutlery and table holloware:
Part 1: Requirements for cutlery for the preparation of food SASO-ISO-8442-1
Part 2: Requirements for stainless steel and silver-plated cutlery SASO-ISO-8442-2
Part 3: Requirements for silver-plated table and decorative holloware SASO-ISO-8442-3
Part 4: Requirements for gold-plated cutlery SASO-ISO-8442-4
Part 5: Specification for sharpness and edge retention test of cutlery SASO-ISO-8442-5
Part 6: Lightly silver-plated table holloware protected by lacquer SASO-ISO-8442-6
Part 7: Requirements for table cutlery made of silver, other precious metals and
their alloysSASO-ISO-8442-7
Part 8: Requirements for silver table and decorative holloware SASO-ISO-8442-8
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List of Standards for Food Contact Tools and Devices
Standard Title Standard No.
Vitreous and porcelain enamels – Release of lead and cadmium from enamelled
ware in contact with food – Part 1: Method of testSASO-ISO-4531-1
General Standard for Contaminants and Toxins in Foods SFDA.FD CAC 193
Food safety management systems – Requirements for bodies providing audit and
certification of food safety management systemsSASO-ISO-TS-22003
Electrically operated food preparation appliances – Methods for measuring
performanceSASO-IEC-60619
Household and similar electrical appliances – Test code for the determination of
airborne acoustical noise – Part 2-14: Particular requirements for refrigerators,
frozen-good storage cabinets and food freezers
SASO-IEC-60704-2-14
Glass containers – Manufacturer – Vocabulary SASO-ISO-7348
Boilers and pressure vessels – Part 2: Procedures for fulfilling the requirements of
ISO 16528-1SASO-ISO-16528-2
Packaging – Sacks – Description and method of measurement – Part 2: Empty
sacks made from thermoplastic flexible filmSASO-ISO-6591-2
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List of Standards for Food Contact Tools and Devices
Standard Title Standard No.
Domestic cooking appliances burning gas. Safety. Appliances having a glass,
ceramic hotplate.SASO-EN-30-1-3
Packaging – Method for specification for sacks – Part 1: Paper sacks SASO-ISO-8351-1
Coating materials for household cooking utensils SASO-GSO-20 14
Plastics – Determination of migrate of plasticizers SASO-ISO-177
Materials and Articles in Contact with Foodstuffs – Insulated Containers for
Domestic Use – Part 2: Specification for Insulated Bags and BoxesSASO GSO EN 12546-2
Ceramic cookware in contact with food – Release of lead and cadmium – Part 2:
Permissible limitsGSO ISO 8391-2
Cookware – Domestic Cookware for use on top of a stove, cooker or hob – Part 2:
Further general requirements and specific requirements for ceramic, glass and
glass ceramic cookware
GSO CEN/TS 12983-2
Edit glass dining utensils – Lead and cadmium – Part 2: Limits allowed GSO ISO 7089-2
Ceramic ware, glass-ceramic ware and glass dinnerware in contact with food –
Release of lead and cadmium – Part 2: Permissible limitsGSO ISO 6486-2
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List of Standards for Food Contact Tools and Devices
Standard Title Standard No.
Cold-formed aluminum household utensils SASO-369
Aluminum and aluminum alloys – Castings – Chemical composition of castings for
use in contact with foodstuffEN 601
Aluminum and aluminum alloys – Wrought products – Chemical composition of
semi-finished products used for the fabrication of articles for use in contact with
foodstuff
EN 602
Sand filters for domestic drinking water treatment SASO 2769
Micro filters for household drinking water purification SASO 2770
Two-piece round tin cans used for packing food materials SASO 2043
Three-piece round tin cans used for material processing SASO 75
Pressure cooker SASO 173