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China Announces the Standard for Food Packaging Adhesives

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On March 12, 2024, China's National Health Commission (NHC) published a batch of new Food Safety National Standards, including the GB 4806.15-2024 for adhesives used in food-contact materials and articles (“Adhesives Standard”). The authority spent almost 10 years to develop this new standard since it was included in the 2014 Plan for Food Safety National Standards. The Adhesives Standard will become effective on February 8, 2025.

Compared with the second draft that was released in 2021, the final version of the Adhesives Standard does not have significant changes in the major provisions. Depending on the intended use, adhesives are classified into two categories: direct food-contact adhesives and indirect food-contact adhesives. Annexes A and B, respectively, provide the positive lists of base materials that may be used in each category. Specifically, Annex A contains 51 polymers that may be used in direct food-contact adhesives; Annex B contains 341 substances (polymers and non-polymeric substances) for use in indirect food-contact adhesives. These non-polymeric substances, approximately 80 in total, may be used as monomers and other starting materials. Polymers formed by the reaction of non-polymeric substances and polymers listed in Annex B are also permitted for use as the base materials for indirect food-contact adhesives, provided that the molecular weight is greater than 1,000 Daltons.

Similar to the other standards for various food-contact materials and articles, the Adhesives Standard requires that additives in adhesives comply with GB 9685 and relevant announcements. It explicitly states in Article 5.1.2 that additives permitted for use in direct food-contact adhesives are also cleared for use in indirect food-contact adhesives.

The Adhesives Standard establishes some general physicochemical specifications for the adhesive layer. In addition to overall migration limit (OML), potassium permanganate consumption, and heavy metals (as Pb), a specification of ≤ 0.01 mg/kg for primary aromatic amines (PAAs), which only applies to adhesives that contain aromatic polyurethanes, etc. that might generate PAAs, is adopted. The testing should be carried out on the finished products of food-contact materials and articles after the curing of adhesives is completed.

The labeling requirements for adhesive products also are prescribed in the Adhesives Standard. In addition to the relevant provisions in GB 4806.1 General Safety Requirements for Food-Contact Materials and Articles, it is specified that adhesive products shall be labeled by the classification, i.e., “direct food-contact adhesive” or “indirect food-contact adhesive.”