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China Industry Association Issues Voluntary Standards for DoC for FCMs

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The China National Food Industry Association (CNFIA) has issued voluntary group standards on Declaration of Compliances (DoCs) for food-contact materials (FCMs). CNFIA was founded as a self-disciplinary management organization for China’s food industry in 1981.
By way of background, China’s GB 4806.1-2016 Standard, “General Safety Requirements on Food Contact Materials and Articles,” sets forth general requirements for a DoC for food-contact materials and articles. Since these requirements do not provide specific requirements, CNFIA has issued more detailed, voluntary guidelines for industry to use when preparing DoCs required under the GB 4806.1 Standard.  
In 2017, CNFIA issued a DoC guidance for the plastics industry. More recently, CNFIA issued the following two voluntary group standards on DoCs for food-contact materials, which came into force on February 10, 2023.

  1. 1T/CNFIA 162-2022 General Rules for Declaration of Compliance of Food Contact Materials and Articles
  2. 2T/CNFIA 163-2022 Requirements for Declaration of Compliance of Adhesives for Food Contact Materials and Articles 

T/CNFIA 162-2022 specifies the applicable scope, relevant definitions and classifications, basic requirements, supply chain stakeholder responsibilities, and principles for DoCs. It also provides examples of DoCs for different products in the food-contact material supply chain, such as chemical substances, intermediate materials, and finished articles.  
T/CNFIA 163-2022 sets forth the responsibilities along the supply chain, basic and special elements, and other items for DoCs for adhesives. Examples of conformity statements include:

  • Compliance with general safety requirements (i.e., the product complies with requirements under GB 4806.1) 
  • Production management (i.e., the product complies with GMP requirements under GB 31603)
  • Compliance with raw materials, additives, and products, assessment of non-intentionally added substances (if necessary)
  • A statement of responsibility

In addition to the above voluntary standards, CNFIA announced its plan to develop a group standard covering DoCs for printing inks used in food-contact materials and articles.