China Announces Draft Amendment to the General Safety Standard for Food-Contact Materials

China’s National Health Commission published a draft amendment to the GB 4806.1, Standard on the General Safety Requirements for Food-Contact Materials and Articles. The GB 4806.1-2016 Standard took effect in 2017, and a prior draft of the amendment was released by the National Center for Food Safety Risk Assessment (CFSA) in April 2023. (For more information on the first draft, see the Packaginglaw.com article, China Proposes to Amend General Safety Standard for Food-Contact Materials.)  

The new Draft Standard retains the concept of “effective barrier” (i.e., the functional barrier doctrine) that was included in the original version. This doctrine permits the use of substances not explicitly listed in the relevant National Food Safety Standards—excluding carcinogens, mutagens, and reproductive toxins (CMR) and nano substances—in food-contact materials and articles outside the barrier, provided that their migration level does not exceed 0.01 mg/kg (10 ppb). The prior draft had proposed a new concept of “complete barrier,” which is not kept in the new draft.

A new section (Section 4.2) that prescribes the requirements for food-contact materials and articles made of multiple types of materials has been added to the most recent Draft Standard. Included is the requirement that each layer of the material in the composite materials and articles comply with the corresponding material standard and the sensory requirements and physicochemical specifications must meet the material standard for the direct food-contact layer.  

The new Draft Standard also provides more details on what should be included in the Declaration of Compliance (DoC). In particular, restricted substances must be listed.

Comments on the second Draft Standard are due by September 26, 2025.