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China Publishes Standards on Food Packaging for Public Comments

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On October 25, 2021, China’s National Health Commission (NHC) published a number of draft GB standards for food and food-related products, including a few key standards for food contact materials of plastics, rubber and adhesives, which are summarized below.

Draft Standard on Food Contact Use Plastic Materials and Articles: This draft standard consolidates two standards currently in place in China that apply to both plastic resins and plastic materials and articles, namely 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. 
Compared with GB 4806.6-2016, which includes 102 permitted plastic resins for food contact uses, the draft Plastic Standard now contains 191 resins. One of the reasons for the increased number of listed resins is that a listing with multiple CAS numbers is now turned into separate listings (e.g., the copolymers of ethylene and various comonomers). The draft Plastic Standard also incorporates the new plastic resins that were approved by NHC since 2013. The starch-based plastic materials and articles for which a draft standard was published in May 2018 also have been incorporated into the draft Plastic Standard. 

Draft Standard on Food Contact Use Adhesives: This is the second draft GB standard on food contact use adhesives that NHC has published. The first draft was released in 2019. This version of the draft Adhesives Standard classifies adhesives into two categories (i.e., direct food-contact and indirect food-contact adhesives). The draft Adhesives Standard deletes the provision from the first version that requires the migration test to be performed on finished food contact materials and articles. Also, the draft Adhesives Standard requires that the product category (i.e., direct food contact adhesives or indirect food-contact adhesives) be declared on the label.

Draft Standard on Food Contact Use Rubber Materials and Articles: The scope of this standard captures food contact materials and articles composed primarily from natural rubber, synthetic rubber, and vulcanized thermoplastic elastomer. The requirements for food contact silicone rubber are deleted as it appears that China will establish a separate standard on silicone rubber.  
The current Rubber Standard contains two positive lists—one of base polymers permitted for use in synthetic rubber and another of base polymers permitted for use in silicone rubber. The draft Rubber Standard deletes the positive list for silicone rubber and contains only one positive list of base raw materials for use in rubber materials and articles (including natural rubber and synthetic rubber). 

Comments on these draft standards are due by November 20, 2021. More information on the draft standards can be found here.