In the News

China Publishes List of New Additives Authorized for Use in Food Packaging

Mar 12, 2009

The People's Republic of China issued on February 11, 2009 a "positive list" of 959 food additives that will be authorized for use in food packaging materials. The list is part of the Hygienic Standard for Uses of Additives in Food Containers and Packaging Materials (GB 9685-2008) that was officially released on November 11, 2008, without the list, by the State Standardization Administration. The new Standard, which replaces GB 9685-2003, has an implementation date of June 1, 2009.

China began updating GB 9685-2003 in late 2005. During of the process, the decision was made to approve a large number of substances as food packaging additives based on a number of criteria, including their clearance status in the United States, the European Union (EU), and Japan. Industry submitted proposals to the Ministry of Health (MOH) for additives it wanted listed. MOH set up a Task Force to review the submissions, and published a draft list in early 2007, which was sent to the World Trade Organization (WTO) in April 2008 for comment by member countries. The new list contains several changes from the 2007 published draft.

New Standard Includes Use Restrictions

The "positive list" of additives approved for specified uses in food containers and packaging materials is included in an Annex to GE 9685-2008. The new Standard specifies that the listed additives may be either: 1) authorized for use without restriction; or 2) be listed with specifications pertaining to "Maximum Permitted Quantity (QM)", "Specific Migration Limit (SML)" and "Not Detectable (ND)". Any additive not on the list, or the use of which does not conform to those specified in the standard, is prohibited for use after June 1, 2009.

The new Standard includes a list of "principles" applicable to the use of additives in food containers and packaging materials. These are:

• Migrating additives and impurities must not present any harm to the health of human beings;
• Migrating additives must not result in changes in food properties (such as ingredients, structure, color, smell or flavor);
• Use levels of additives in food containers and packaging materials should not exceed that necessary to achieve the intended technical effect; and
• Additives must comply with relevant quality specifications/standards.

Specific migration limits and other specifications are to be determined by test methods to be designated by MOH. However, if China has not specified a standardized test method, then methods officially recognized by the U.S. or EU will be acceptable. For additives not included in GB 9685-2008, MOH is expected to issue in the near future an administrative clearance procedure—along with data requirements—for the approval of new additives and polymers.

Chinese authorities are not expected to object to the use of any of the listed additives prior to the "implementation date" of June 1, 2009. However, since the new list is currently only available in the Chinese language, understanding restrictions and specifications for use will require knowledge of the language.