The analysis of latest Chinese food contact material regulation
NHFPC has announced the No.15 document about releasing GB 9685-2016《Standard for uses of additives in food contact materials and their articles 》and other 52 national food safety standards on November 18th, 2016, which indicate the completing of Chinese food contact material regulation and the regulatory framework has been established (figure 1). This article will share and analysis the up-to-date Chinese food contact material regulatory system to supply chain and stakeholders in this field:
Figure 1 Food contact material regulatory system in China
1. Classification of regulations
According to current regulation system, food contact material regulations can be divided into the following four categories, which including:
- basic standards (2 items)
- article standards(10 items)
- test method standards (51 items)
- manufacturing practice standards (1 items)
2. Implementation date
The specific implementation date of the standards would be different because of the difference of issue date. It’s significant for the supply chain to know the implementation date, so we have sorted out the implementation date of each standard,
l the standards have been implemented
- GB 31603-2015 Good manufacturing practice for food contact materials and articles
- GB 31604.1-2016 General principles for migration experiment
- GB 4806.2-2015 Nipple
l Standards to be implemented on March 1, 2017
- GB 31604.2-10 -2016 series standards are the standards for migration test , which include potassium permanganate consumption, resin drying shrinkage, determination of volatile matter and ignition residue in resin, decolorization experiment, overall migration, heavy metal in food simulant and bisphenol A (BPA).
l The standard to be implemented on April 19, 2017
- GB 4806.3-11 series——article standards
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GB 4806.3-2016 |
National Food Safety Standard Enamelled articles |
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GB 4806.4-2016 |
National Food Safety Standard Ceramic articles |
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GB 4806.5-2016 |
National Food Safety Standard Glass articles |
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GB 4806.6-2016 |
National Food Safety Standard Resins in plastic food contact materials |
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GB 4806.7-2016 |
National Food Safety Standard Plastic food contact materials and articles |
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GB 4806.8-2016 |
National Food Safety Standard Paper, paperboard food contact materials and articles |
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GB 4806.9-2016 |
National Food Safety Standard Metal food contact materials and articles |
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GB 4806.10-2016 |
National Food Safety Standard Painting and coating in food contact materials and articles |
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GB 4806.11-2016 |
National Food Safety Standard Rubber food contact materials and articles |
- Testing method standard
- GB 5008.156-2016 General rules of the pre-treatment method of the migration test for food contact materials and articles
- GB 4789.15-2016 Mould and yeast detection of food articles
- GB 31604.2-49 series standards
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GB 4806.11-2016 |
National Food Safety Standard Rubber food contact materials and articles |
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GB 31604.11-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for 1,3-bis(aminomethyl)benzene |
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GB 31604.12-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for 1,3-butadiene |
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GB 31604.13-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for 11-aminoundecanoic acid |
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GB 31604.14-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for 1-octene and tetrahydrofuran |
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GB 31604.15-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for melamine |
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GB 31604.16-2016 |
National Food Safety Standard Food contact material and articles Measurement for styrene and ethylenzene |
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GB 31604.17-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for acrylonitrile |
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GB 31604.18-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for acrylamide |
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GB 31604.19-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for 2-oxohexamethylenimine |
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GB 31604.20-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for vinyl acetate |
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GB 31604.21-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for terephthalic acid |
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GB 31604.22-2016 |
National Food Safety Standard Food contact material and articles Measurement for dichlorodifluoromethane in expanded polystyrene articles |
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GB 31604.23-2016 |
National Food Safety Standard Food contact material and articles Measurement for 2,3-diaminotoluene in compound food contact material |
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GB 31604.24-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for cadmium |
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GB 31604.25-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for chromium |
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GB 31604.26-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for epichlorohydrin |
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GB 31604.27-2016 |
National Food Safety Standard Food contact material and articles Measurement for ethylene oxide and propylene oxide in plastic |
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GB 31604.28-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for bis(2-ethylhexyl) adipate |
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GB 31604.29-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for methyl methacrylate |
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GB 31604.30-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for phthalates |
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GB 31604.31-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for vinyl chloride |
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GB 31604.32-2016 |
National Food Safety Standard Food contact material and articles Measurement for sulfur dioxide in wood materials |
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GB 31604.33-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for nickel |
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GB 31604.34-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for plumbum |
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GB 31604.35-2016 |
National Food Safety Standard Food contact material and articles Measurement for heptadecafluorooctanesulfonic acid (PFOS) and pentadecafluorooctanoic acid (PFOA) |
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GB 31604.36-2016 |
National Food Safety Standard Food contact material and articles Measurement for creosote in cork |
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GB 31604.37-2016 |
National Food Safety Standard Food contact material and articles Measuremen for triethylamine and tributylamine |
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GB 31604.38-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test for arsenic |
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GB 31604.39-2016 |
National Food Safety Standard Food contact material and articles Measurement for 2,3′,4,4′,5-pentachlorobiphenyl in paper food contact material |
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GB 31604.40-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for maleic acid and maleic anhydride |
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GB 31604.41-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for stibium |
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GB 31604.42-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for zinc |
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GB 31604.43-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for ethylenediamine and 1,6-hexanediamine |
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GB 31604.44-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for ethylene glycol and diethylene glycol |
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GB 31604.45-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for isocyanic acid |
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GB 31604.46-2016 |
National Food Safety Standard Food contact material and articles Measurement and volume of migration test forfree phenol |
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GB 31604.47-2016 |
National Food Safety Standard Food contact material and articles Measurement for fluorescent brightener in paper, paperboard and their articles |
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GB 31604.48-2016 |
National Food Safety Standard Food contact material and articles Volume of migration test for formaldehyde |
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GB 31604.49-2016 |
National Food Safety Standard Food contact material and articles Measurement for arsenic, cadmium, chromium, plumbum and volume of migration test for arsenic, cadmium, chromium, nickel, plumbum, stibonium,zinc |
l The standard to be implemented on October 19, 2017
- GB 4806.1-2016 General safety requirements for food contact materials and articles
- GB 9685-2016 Standard for uses of additives in food contact materials and their articles
3. Compliance suggestions
Food Safety Law and new-released National Food Safety Standard General safety requirements of food contact material and articles（GB 4806.1-2016） series have provided new compliance perspectives and requirements for the relative enterprises in whole supply chain. We have summarized and analyzed compliance suggestions for each role in the supply chain under the new regulation system:
- Raw material producers
Articles need to be listed in the corresponding list, such as additives must be listed in the Appendix of GB 9685-2016, resin standards need to meet the requirements of GB 4806.6-2016 and related announcements. And articles should comply with the corresponding manufacturing specifications (GB 31603-2015 General specification of food contact materials and articles), and pass downstream declarations of compliance( DoC);
² If the substance is not listed in the relative list, this new substance has to submit an – application and can be used only after assessment.
- Intermediate article producers
The selected raw materials and additives need to meet the relevant national standards. Articles need to meet the corresponding standards and be in line with the corresponding manufacturing specifications and pass downstream declarations of compliance ( DoC).
- Finished article manufacturers
Finished article manufacturers also need to select the raw materials and additives to meet the relevant national standards, make corresponding articles testing and pass downstream declaration of compliance (DoC).
- Customer
To ensure the safety of food, customers should use the article in accordance with the declaration of compliance (DoC) passed from upstream.
In this article, we have interpreted the framework of Chinese food contact material regulation and provided some regulatory compliance suggestions. In order to – help relative enterprises deal with this regulatory updates , we will also interpret GB 9685-2016 National Food Safety Standard Standards for uses of additives in food contact materials and their articles , National Food Safety Standard General safety requirements of food contact material and articles（GB 4806.1-2016）in recent days.
