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How to Comply with Food Contact Regulations in China

By Little Pro on 2017-04-07 Views:  Update:2017-04-24

In China, food contact materials and articles (FCMs) include various materials and products that come into contact food or are expected to come into contact with food under normal and foreseeable use conditions. To be more specific, they include packaging materials, containers, tools and equipment as well as printing inks, adhesives, lubricating oils, etc. possibly contacting foods directly or indirectly that are used during food production, processing, packaging, transportation, storage, sale and usage processes (excluding detergents, disinfectants and public water-transporting facilities). In this article, we will give an introduction to how to comply with food contact regulations in China with a focus on general requirements for food contact materials, food contact additives, and specific types of food contact materials and articles.

Overview of China's Food Contact Legislation

Food contact materials (FCMs) are regulated as food-related products in China. The China Food Safety Law prohibits the importation, use or sales of food-related products (e.g., food additive, food packaging materials) not compliant with applicable national Food Safety Standards. In Nov 2016, the National Health and Family Planning Commission (NHFPC) published 53 consolidated national food safety standards related to food contact materials and food contact additives. Those food safety standards consititute a complete regulatory framework for food contact materials in China.

Those 53 national standards can be divided into 4 categories (see table below):

Category Description

1 standard for general requirement

 

  • GB 4806.1-2016 National Food Safety Standard: General Safety Requirements on Food Contact Materials and Articles.
  • It sets out general safety requirements which apply to all kinds of food contact materials and articles. 
  • Entry into force: 19 Oct 2017

1 standard for food contact additive

 

  • GB 9685-2016 National Food Safety Standard: Standard for the Use of Additives in Food Contact Materials and Articles;
  • It sets out a positive list of additives that can be used to produce various food contact materials and articles, their use scope and restrictions. 
  • Replaces GB 9685-2008.
  • Entry into force: 19 Oct 2017

10 standards for specific types of materials and articles

 

  • GB 4806.3-2016 National food safety standard for enamel products
  • GB 4806.4-2016 National food safety standard for ceramic products
  • GB 4806.5-2016 National food safety standard for glass products
  • GB 4806.6-2016 National food safety standard - plastic resins for food contact use
  • GB 4806.7-2016 National food safety standard - plastic materials and articles for food contact use
  • GB 4806.8-2016 National food safety standard - paper and paperboard for food contact use
  • GB 4806.9-2016 National food safety standard - metallic materials and articles for foodcontact use
  • GB 4806.10-2016 National food safety standards - paints and coatings for food contact use
  • GB 4806.11-2016 National food safety standards - rubber materials and products for food contact use
  • GB 14934-2016 National food safety standards - Disinfection tableware

41 standards for testing methods

 

  • GB 5009.156-2016 National food safety standards -  general principles of pretreatment methods for migration test of food contact materials and articles
  • GB31604.1-2015 National food safety standards - general principles for migration test of food contact materials and articles.
  • GB 31604.49-2016 Determination of arsenic, cadmium, chromium, lead and determination of arsenic, cadmium, chromium, nickel, lead, antimony and zinc in foodcontact materials and articles; and
  • Other testing methods for the testing of the migration of specific hazardous substances formaldehyde, Pb, etc.

If you wish to purchase the English version of any standard above for a small fee, please contact us. Quality is guaranteed.

GB 4806.1-2016: General Safety Requirements for FCMs

The main requirements of GB 4806.1-2016 that apply to all types of food contact materials are listed as follows:

  • FCMs shall not release their constituents into food at levels harmful to human health or change food composition, taste and odour;
  • The production of food contact materials and their products shall meet the requirements of GB 31603-2015 National Food Safety Standard General Hygienic Practice for Production of Food Contact Materials and Its Products;
  • Food contact materials and food contact additives must comply with relevant restriction conditions in relevant food safety standards.
  • Producers must establish a traceability system for FCMs from production to distribution;
  • Product information: Food contact materials must be accompanied with sufficient product information when they are sold. This includes product name, material, declaration of conformity to relevant laws, regulations and standards; name, address and contact information of the producer and (or) dealer, production date, warranty period (if applicable), instruction for use, and qualification certificate. 
  • Labelling: Food contact materials and their final products shall be labelled with  "food contact use", "used as food packaging", or be printed or pasted with the sign of spoon or chopsticks (see picture below). Obvious food contact articles such do not require such labelling.
  • Food Contact Regulations China

More info about this standard can be found here. If you wish to purchase the English version of this standard for a small fee, please contact us. Quality is guaranteed.

GB 9685-2016: Positive List of Food Contact Additives

GB 9685 specifies a list of additives that are permitted for use in various food contact materials and articles. The use of additives in food contact materials and their products shall simultaneously meet the requirements of Appendixes A, B and C in GB 9685. New food contact additives or new use must be approved by NHFPC first before they can be used to produce food contact materials and articles. 

  • Appendix A: list of permitted additives and use restrctions, grouped by the type of food contact materials (from A1 to A7);
  • Appendix B: requirements on total specific migration limit;
  • Appendix C: special limitation of metallic elements.

Appendix A includes 7 tables. 

  • A1: permitted additives for plastic food contact materials and articles
  • A2: permitted additives for paints and coatings for food contact use
  • A3: permitted additives for rubber food contact materials and articles
  • A4: permitted additives for printing inks for food contact use
  • A5: permitted additives for adhesives for food contact use
  • A6: permitted additives for paper and board for food contact use
  • A7: permitted additives for other materials such as silicon rubber.

For each additive, its Chinese name, CAS no., use scope, maximum use level, specific migration limit (SML) or maximum residue (QM) and other requirements are given (see example for A1 below).

GB 9685-2016

More info about this standard can be found here. If you wish to purchase the English version of this standard in for a small fee, please contact us. Quality is guaranteed.

GB 4806.7-2016: Standard for Plastic Food Contact Materials

For each type of food contact materials or articles, there are more specific requirements. We will use GB 4806.7-2016 as example to show you what those requirements look like (i.e, plastics).

Item Requirements
General requirements
  • Follow GB 4806.1;
Raw materials
  • Resins used follow 4806.6;
  • Additives follow GB 9685;
Sensory requirements
  • Normal color, no odor, etc.
  • More can be found in GB 4806.7
Physio-chemical properties
  • Overall migration limit <=10mg/dm2;
  • Pb<=1mg/kg;
  • More can be found in GB 4806.7
Labeling
  • Follow GB 4806.1; and 
  • Indicate resins used;

How to Demonstrate Compliance with Food Contact Regulations in China

Who How
Manufacturer and supplier of food contact additive
  • Check if additives are listed in GB 9685 and whether they have been permitted for use in a specific type of food contact materials or articles.
  • Notify new food contact addtivies if applicable. 
Manufacturer of food contact materials and articles
  • Check if raw materials (additives, resins) have been permitted for use in the production of a specific type of food contact materials or articles.
  • Comply with GB 4806.1-2016 general safety requirements for FCMs and GB 31603-2015 National Food Safety Standard General Hygienic Practice for Production of Food Contact Materials and Its Products; 
  • Make each type of food contact material or article compies with corresponding food safety standard;
  • Conduct migration testing to verify compliance if necessary;
  • Provide enough product information to downstream users including the declaration of compliance and labelling.
Food packaging or food companies
  • Request enough product information from the supplier of food contact materials and articles including the declaration of compliance.
  • Conduct migration testing to verify compliance if necessary.

Reference

 

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