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China Announces New Food Safety Standards, Including Ones for Food-Contact Materials

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On September 25, 2023, China’s National Health Commission (NHC) published 85 National Food Safety Standards for food, food additives, food-related products, and various testing methods. Below is a brief summary of the key food-contact standards, including one of migration testing.

GB 4806.7-2023 National Food Safety Standard on Food-Contact Use Plastic Materials and Articles (Plastics Standard): The amended Plastics Standard consolidates two standards currently in place that apply to both plastic resins and plastic materials and articles: GB 4806.6-2016 National Food Safety Standard on Food-Contact Use Plastic Resins and GB 4806.7-2016 National Food Safety Standard on Food-Contact Use Plastic Materials and Articles. It contains 187 resins, compared to 102 in GB 4806.6-2016. The group listings for ethylene and propylene copolymers in GB 4806.6-2016 are turned into separate listings. Further, it is stated that sodium, potassium, and calcium salts of acids, alcohols, and phenols that are starting monomers of polymers may also be used in the synthesis of corresponding polymers. The amended Plastics Standard also includes a new specification on the total migration of primary aromatic amines (PAAs), and it permits the use of both edible and modified starches in the production of starch-based plastic materials and articles. 

GB 4806.9-2023 National Food Safety Standard on Food-Contact Use Metal Materials and Articles (Metal Standard): The amended Metal Standard prescribes more requirements on raw materials than GB 4806.9-2016. The migration specifications for impurity elements and alloy elements are revised, and the limits for many elements are significantly lowered. The residual limits on arsenic, lead, cadmium, and/or mercury for various types of metal materials are set forth in Table 1. 

GB 4806.11-2023 National Food Safety Standard on Food-Contact Use Rubber Materials and Articles (Rubber Standard): The scope of the amended Rubber Standard captures food-contact materials and articles composed primarily from natural rubber, synthetic rubber, or vulcanized thermoplastic elastomers. Silicone rubbers have been removed from the amended Rubber Standard and will be covered by a separate standard. The positive list of base materials for synthetic rubbers is kept in Appendix A and contains a total of 45 substances. The default fatty food simulant for food-contact rubber materials and articles is changed from 50% ethanol to vegetable oil. However, 50% ethanol may still be used in case that testing with vegetable oil is not technically feasible or changes in the physical properties of the testing sample occur.

GB 4806.13-2023 National Food Safety Standard on Food-Contact Use Composite Materials and Articles (Composite Materials Standard): The Composite Materials Standard applies to “food-contact materials and articles with two or more layers made from different or same materials by adhesion, hot melting or other ways.” Substances used in each layer must comply with the corresponding GB standard. In addition to physicochemical specifications and microbial specifications, the Composite Materials Standard also requires that the label of composite materials and articles identify, from the exterior layer to the direct food-contact layer, the type of material for each layer.

GB 4806.14-2023 National Food Safety Standard on Food-Contact Use Printing Inks (Printing Inks Standard): The Printing Inks Standard is a new standard and applies to both printing inks in direct contact with food and ones that indirectly contact food where the components may transfer to the food. It also captures the varnish that is used together with printing inks. It does not contain a positive list of substances but sets out some general requirements for the raw materials. In addition, the Printing Inks Standard establishes residual limits for heavy metals (lead, mercury, cadmium, chromium, and arsenic) in printing inks, and it sets out specifications on the overall migration, the migration of PAAs, etc.

GB 31604.1-2023 National Food Safety Standard on the General Rules for Migration Testing for Food-Contact Materials and Articles (Migration Testing Standard): The amended Migration Testing Standard is different from the current version in various ways. Among other things, the amended Migration Testing Standard prescribes that 10% ethanol can be used for overall migration testing to cover all food types even if foods with higher alcohol contents are contemplated. It also allows migration testing to be performed using only the “worst case” simulant provided there is scientific evidence that this simulant will yield the most severe migration condition. In the amended Migration Testing Standard, dry food is explicitly designated as a separate food category. Migration testing for materials and articles in contact with dry food should be conducted on the food per se, or if analysis in the actual food is not feasible, one may choose to use at least one simulant designated for the other food types.   

NHC provides a one-year transition period for these six food-contact standards, all of which will become effective from September 6, 2024.