China Publishes Food-Contact Coatings and Silicon Rubber Standards
China’s National Health Commission (NHC) recently published the final versions of two food-contact standards: Coatings Standard (GB 4806.10-2025) and Silicone Rubber Standard (GB 4806.16-2025). Both are scheduled to be effective on September 2, 2026.
The new Coatings Standard is an amendment of the current version (GB 4806.10-2016), which was published in 2016. It expanded the scope of the 2016 version to cover both direct food-contact and indirect food-contact coatings. Further, the amended Coatings Standard removed the exclusion of paper coatings and coating layers. As a result, it applies to coatings and coating layers that directly and indirectly contact food.
The positive list of base materials for food-contact coatings and coating layers in Appendix A has been expanded from 105 polymers to 346 substances and includes more than 60 non-polymeric substances that may be used as monomers and other starting reactants. Also, listed monomers, other starting reactants, and polymers may react with each other to create new polymers for use in food-contact coatings and coating layers, provided that the molecular weight of the reacted polymer is greater than 1000 Daltons. Further, when the listed monomers and other starting reactants are acids, alcohols, or phenols, their sodium, potassium, and calcium salts also may be used.
The amended Coatings Standard includes a new specification of primary aromatic amines (PAA) total migration that is applicable to coatings containing aromatic isocyanates and azo colorants. The total migration of PAA should not be detected at a limit of detection (LOD) of 0.01 mg/kg.
Silicone rubbers for food-contact applications were regulated together with rubbers until the prior Rubber Standard (GB 4806.9-2016) was amended in 2023 to only cover rubbers. The portion of GB 4806.9-2016 that is relevant to silicone rubbers will be replaced by the new Silicone Rubber Standard.
Food-contact use silicone rubber materials and articles are defined as materials and articles whose main raw materials are silicone elastomers formed by cross-linking and curing of polysiloxane polymers and hydrophobic silica, etc., which contact or may contact food or food additives, or whose components may transfer into food under the expected conditions of use. A total of 21 substances are listed in Table A.1 for use as the base raw materials, which are allowed to react with each other to create new polymers, provided that the molecular weight of the reacted polymer is greater than 1000 Daltons. If the listed monomers and other starting reactants are acids, alcohols, and phenols, their sodium, potassium, and calcium salts also may be used.
The physicochemical specifications for silicone rubbers include overall migration, potassium permanganate consumption, heavy metals, and volatile substances. The overall migration testing conditions for silicone rubbers that are used in contact with food at temperatures below 40ºC for less than 24 hours are also provided.