In late 2016 China finalised two new food contact packaging standards.
The first is an updated edition of GB 9685, the Chinese national standard for additives used in food packaging materials and articles.
The GB 9685 definition of food contact materials and articles includes inks, adhesives, lubricating oils, and any other substance that may directly or indirectly contact food.
The revised scope of the Chinese document captures monomers for certain base polymers and other starting materials of polymerisation.
The core of the standard is Appendix A, which contains 1,294 authorised substances. This includes more than 340 new approvals issued since the last version of the standard was released in 2008. The positive list of substances is now separated into tables for each packaging material:
- Printing inks
- Silicone rubbers
In addition, the existing clearances for more than 200 other listed additives have been expanded.
The amended GB 9685 also contains a number of categorical clearances for unlisted substances.
Appendix B contains restrictions on total specific migration. The maximum permitted sum of two or more substances released into food or food simulants is expressed in terms of a designated substance, or category of substances. The limits are derived from the EU’s Regulation 10/2011 on plastic materials and articles for food contact.
The standard contains three other appendices:
- Appendix C lists specific migration limits for certain metal elements
- Appendix D offers an index of abbreviations used for plastic materials, along with their English and Chinese names
- Appendix E lists all the approved additives by CAS number and by their names in Chinese.
General safety requirements
The second new Chinese standard is GB 4806.1-2016 on General Safety Requirements for Food Contact Materials and Articles (GSS).
The standard puts in place a new definition for a functional barrier: the migration of unlisted substance from layers behind a barrier into foods must not exceed 0.01mg/kg – 10 parts per billion. Known carcinogens, mutagens, reproductive toxins and nanomaterials are not allowed regardless of migration level. Manufacturers must perform a safety assessment and control unlisted substances behind the functional barrier.
The final general safety standard also defines impurities in food contact materials as substances that are not intentionally added (NIAS), including those derived from raw and auxiliary materials, decomposition products, pollutants, and residual reaction intermediates resulting from production and use. In a significant reversal, GB 4806 does not demand a formal safety assessment of NIAS.
The new standards are part of a general modernisation and tightening of China’s approach to regulating the safety of food contact materials. In the past five years, a total of 134 petitions have been filed under China’s revised management rules; 78 have been approved.
Food Contact compliance expert Dr Alistair Irvine of Smithers Pira comments, “the new structure that has been introduced into GB 9685 together with the additional substances added to the positive list are welcome moves that will help make China’s food contact regulations much easier to use and more comparable to other standards such as EU Regulation 10/2011.”
Dr Irvine continues, “The new outlined requirements are a great step towards updating and consolidating the organisation of the country’s food packaging standards.”
The standards will take effect in April and October 2017.
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