China Consults on Two Key GB Standards for Food Contact Materials

On October 18, 2023, the National Health Commission (NHC) unveiled the consultation drafts of 11 national food safety (GB) standards, including two significant standards related to food contact materials (FCM), namely, the proposed revised version of GB 4806.1 General Safety Requirements for Food Contact Materials and Articles, and the newly formulated GB 4806. XX Silicon Rubber Materials and Articles in Contact with Foodstuffs. Any public comments can be submitted via the online system before December 15. The details of the standards are as follows:

1. The Proposed Revised GB 4806.1 

As the primary overarching standard for FCM among Chinese legislations, GB 4806.1 applies to all types of FCM. In April 2023, China proposed the first revision of GB 4806.1 after its implementation for seven years (Click for ChemLinked News). Based on feedback received regarding the first revision, the NHC has proposed this new version and is now seeking public comments again. The new version is largely consistent with the first version but includes several minor revisions:

Terms and definitions

The new version introduces more precise definitions for certain terms, such as "food contact materials and articles," "effective barrier," and "complete barrier."

Raw material requirements

The first version specified that "permitted polymer materials such as plastics, rubber, silicone rubber, coatings, adhesives, and inks are allowed to be blended without chemical reactions". However, this provision is removed in the new version. Additionally, the new version states that "substances not listed in the standards and announcements can be used for the production of food contact materials and articles on the outer side of the complete barrier."

Limit requirements

In cases where the same substance (group) has both Specific Migration Limits, either Specific Migration Limits (SML) or Total Specific Migration Limits (SML (T)), and Maximum Permitted Quantity (QM), the new version clarifies that SML or SML(T) should be used with priority for compliance verification.

Labeling requirements

The previous version required that labels be prominently displayed on the smallest unit of food contact materials and articles. The new version adds a provision, stating that if it is technically not feasible to display all information on the smallest sales unit, the information can be provided in the product manual or accompanying documents.

Declaration of Conformity

The new draft emphasizes that producers and business operators of food contact materials and articles should provide Declaration of Conformity to downstream stakeholders.

2. Newly Drafted GB Standard for Silicon Rubber Materials and Articles 

While the GB standard is newly proposed, it is important to note that the it is based on GB 4806.11 Rubber Materials and Articles in Contact with Foodstuffs. Given the differences in material characteristics and processing technology between silicone rubber as well as rubber materials and articles, this separate standard has been established, incorporating revisions to GB 4806.11 in various aspects, including application scope, terms and definitions, technical requirements, migration testing, and labeling.

The basic requirements and labeling requirements are quoted from GB 4806.1 General Safety Requirements for Food Contact Materials and Articles, and the use of additives complies with GB 9685 Standard for Uses of Additives in Food Contact Materials and Articles and relevant announcements. The basic requirements for migration testing follow GB 31604.1 General Rules for Migration Test of Food Contact Materials and Articles and GB 5009.156 General Principle to the Pretreatment for Migration Test of Materials and Articles in Contact with Food, while the special provisions for migration testing in GB 4806.11 will be applied based on the characteristics of silicone rubber products.

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