Regulatory Compliance Service China Food Contact Materials and Articles

Mar. 20th, 2019
5254

 

1. What are food contact materials and articles?

Definition:

All materials and articles which have contacted or are expected to come in contact with food or food additives, and may transfer to food when used under the intended conditions.

Including:

(1) food packaging materials, containers, utensils and machines that directly contact food during food production, processing, packaging, transportation, storage and selling;

(2) printing ink, adhesive, grease that may directly or indirectly contact food;

Not Including:(1) detergents; (2) disinfectors; (3) public water delivery

Food contact materials and articles VS Food relative products

2. Relevant Standards for China food contact materials and articles

Basic standards: GB9685-2016 Standard for Uses of Additives for Food Contact Materials and Articles
GB 4806.1-2016 General Safety Requirements for Food Contact Materials and Articles
Product standards: Enamelled Articles, Ceramic Articles, Glass Articles, Plastic Resins, Plastic Materials and Articles, Paper
and Cardboard, Metal Materials and Articles, Paint and Coating, Rubber Materials and Articles
Testing standards:
GB 31604.1-2015 General Principle for Migration Test of food contact materials and articles
GB 5009.156-2016 General Principle to the Pretreatment for Migration Test of food contact materials and articles
Other test standards matching detection indexes
Manufacturing standards: GB 31603-2015 Good Manufacturing Practice for Food Contact Materials and Articles

3. Food contact materials and articles regulatory compliance

(1) What kinds of substance need a Declaration of Compliance?

  • Substances listed in the national standard positive list
  • Substances permitted by NHC as an announcement

(2) What kinds of substance need to conduct a New Substance Application?

  • Food packaging materials, containers and their additives not listed in the national standard positive list or not permitted by NHC as an announcement.
  • Food packaging materials, containers and additives intended to expand the scope of applications or the dosage.
  • New food contact materials and additives used in tools and equipment during food production or marketing.

4. Application workflow for new food contact materials and articles

Our service

  • Food contact materials regulation consulting/customized consulting report
  • New food contact substances application
  • Regulatory compliance analysis/new substance judgement
  • Declaration of Compliance (DoC) editing/auditing
  • Lab selection and supervision of testing
  • Regulatory compliance training
  • Regulations translation
  • Consult with competent authority
  • Supplier management