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Express of China’s New Food Contact Material Standards : will be implemented on 2024

On September 25, 2023, the National Health Commission of PRC issued 85 national food safety standards and 3 amendments (Announcement No. 6 of 2023 by the Health Commission). Among them, 17 standards are related to food contact materials, including 5 product standards (plastic, metal, rubber, composite materials, ink) and 12 method standards (migration general principles, method validation general principles, specific migration test methods, etc.)

The implementation dates for the 5 food contact product standards and their old standards that are being replaced are as follows in the table:

Standard Type

No.

Standard Number

Standard Name

Substitute Standard Number

Implementation Date

Products Standard

1

GB 4806.7-2023

National Food Safety Standard – Food Contact Plastic Materials and Products

GB 4806.6-2016
GB 4806.7-2016

2024.9.6

2

GB 4806.9-2023

National Food Safety Standard – Metal Materials and Products for Food Contact

GB 4806.9-2016

2024.9.6

3

GB 4806.11-2023

National Food Safety Standard – Rubber Materials and Products for Food Contact

GB 4806.11-2016
(Rubber part)

2024.9.6

4

GB 4806.13-2023

National Food Safety Standard for Food Contact Composite Materials and Articles

GB 9683-1988

2024.9.6

5

GB 4806.14-2023

National Food Safety Standard for Inks Used in Food Contact Materials and Articles

New Added

2024.9.6

 

Among these, the standards most relevant to composite materials are GB 4806.13-2023 'National Food Safety Standard for Food Contact Composite Materials and Articles' and GB 4806.14-2023 'National Food Safety Standard for Inks Used in Food Contact Materials and Articles.' In comparison to the standards they replace, the main changes are as follows:

 

PART I.  GB 4806.13-2023 'National Food Safety Standard for Food Contact Composite Materials and Articles

Key Revisions

In comparison to GB 9683-1988, GB 4806.13-2023 presents several changes in the following aspects:

    1. Modification of the Standard Title

In accordance with the new national food safety standard naming conventions, the standard title of GB 4806.13 has been designated as 'National Food Safety Standard for Food Contact Composite Materials and Articles.'

    2. Expansion of the Applicability

GB 9683-1988 was only applicable to composite packaging bags made by bonding paper, plastic films, or aluminum foil using adhesives (polyurethane and modified polypropylene), including cooking bags and regular composite bags. GB 4806.13 has expanded its applicability to various food contact composite materials and products.

    3. Addition of Terminology, Definitions, Raw Material Requirements, and Sensory Requirements

(1) The definition of 'food contact composite materials and articles' has been added. 

(2) It is now required that each layer of materials and the basic resins, additives, and other materials used comply with relevant national food safety standards and related announcements. 

(3) Sensory requirements for materials directly in contact with food have been added in accordance with the corresponding national food safety standards.

    4. Revised Physical and Chemical Criteria

(1) General Physical and Chemical Criteria:

    • Food contact composite materials and products should comply with the relevant national food safety standards' general physical and chemical criteria for each layer of materials (direct food contact layer and outer layer).

    • When multiple layers share the same item, the limit values for that item are determined according to the provisions of GB 4806.1.

    • Total migration, potassium permanganate consumption, heavy metals (expressed as Pb), and decolorization testing items, which are screening criteria, are significantly influenced by the direct food contact layer. Therefore, they are regulated in accordance with the relevant national food safety standards for the materials of the direct food contact layer.

        (2) Other Physical and Chemical Criteria: 

    • Food contact composite materials and products must also ensure compliance with specific migration limits (SML) and total specific migration limits (SML(T)) and other physical and chemical criteria according to the relevant national food safety standards for each layer of materials and related announcements.

    • Residue criteria and maximum residue limits (QM) apply only to the specific layer; testing the entire composite product for residue is not reasonable.

    • Food contact composite materials and products that use coatings, inks, and/or adhesives should also comply with the relevant food safety standards and other physical and chemical criteria.

    • When the same item is specified for multiple layers of materials, the limit values are determined in accordance with the provisions of GB 4806.1-2016.

    5. Addition of Microbiological Limits

Microbiological limits for food contact composite materials and products expected to come into direct contact with food, and which are used without disinfection or washing, should comply with the provisions of GB 14934. This requirement excludes food contact composite materials and products intended for foods that require peeling, shelling, or washing before consumption, cooking, or processing. GB 14934 specifies requirements for two types of microorganisms: Escherichia coli and Salmonella.

    6. Addition of Migration Testing Requirements

Migration testing should be conducted in accordance with the provisions of GB 31604.1 and GB 5009.156.

    7. Addition of Labeling Requirements

(1) To ensure alignment with the framework standard, labeling of composite materials and products should comply with the requirements of GB 4806.1. 
(2) In accordance with industry recommendations, product labels should indicate the material names in order from the outermost layer to the inner layer (direct food contact layer), including inks, adhesives, and coatings, using a forward slash (“/”) as a separator. The specific method of labeling for each layer of material should be in accordance with the relevant national food safety standards' provisions. 

(3) When food contact composite materials have special usage requirements, these should be indicated in the product information.

 

PART II.  GB 4806.14-2023 'National Food Safety Standard for Inks Used in Food Contact Materials and Articles'

    1. Scope Application

Scope applicable to inks used for food contact materials and products, including the printing ink layers they form.

    2. Raw Material Requirements

(1) The base materials and additives used for direct food contact inks should be substances listed in GB 2760 and related announcements.

(2) Inks used for indirect food contact should not contain colorants based on lead, mercury, cadmium, chromium (VI), arsenic, antimony, selenium elements, or their compounds. The colorants used must comply with the requirements of GB 9685.

(3) Other base materials should be approved for use in food contact materials in China.

    3. Physical and Chemical Criteria

(1) Sensory and immersion fluid;

(2) Residue limits for heavy metals in inks (lead, mercury, cadmium, chromium, arsenic);

(3) Physical and chemical criteria for printing ink layers (total migration, potassium permanganate consumption, heavy metals expressed as Pb, aromatic amine migration).


PART III.  The simultaneous release of so many food contact product-related standards by the National Health Commission will have a significant impact on related manufacturing companies. Especially considering that the five aforementioned food contact materials and product standards will officially be implemented on September 6, 2024, with less than a year remaining in the transition period, it is essential for businesses to take early measures to adapt.

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