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Two Key China Food Packaging Standards Now In Effect

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China’s revised Additives Standard (GB 9685 Standard on the Uses of Additives in Food-Contact Materials and Articles) and the General Safety Standard (GB 4806.1 Standard on General Safety Requirements for Food-Contact Materials and Articles) took effect on October 19, 2017. 

While the revisions and changes to the updated GB 9685 Standard are discussed in previous articles (available here and here), the new General Safety Standard has several sections that are worth highlighting. Specifically, Sections 8.1 to 8.6 of this Standard require companies marketing food-contact materials in China to provide to a Declaration of Compliance (DoC) their downstream customers.

Another new concept that China has now formally adopted is the ability to use substances that are not explicitly listed within applicable GB standards, provided there is a functional barrier between the unlisted substance and the food, and certain other criteria are met. (More details on these requirements can be found here.) While caution should be used in determining whether a substance can be used in accordance with the functional barrier concept set forth in the General Safety Standard, it does provide industry with some flexibility to market substances without obtaining premarket approval under appropriate circumstances on a case-by-case basis.

In addition to the two food packaging standards noted above, several other key food packaging standards took effect earlier this year, on April 19, 2017. These are: 

● GB 4806.3-2016, Food-Contact Use Enameled Articles

● GB 4806.6-2016 Food-Contact Use Plastic Resins 

● GB 4806.7-2016 Food-Contact Use Plastic Materials and Articles

● GB 4806.8-2016 Food-Contact Use Paper, Paperboard and Paper Articles

● GB 4806.9-2016 Food-Contact Use Metal Materials and Articles

● GB 4806.10-2016 Food-Contact Use Coatings and Coating Layers

● GB 4806.11-2016 Food-Contact Use Rubber Materials and Articles

Importantly, these food packaging Standards—revised and updated by the China's National Health and Family Planning Commission (NHFPC) over the last several years—are now effective.