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China Drafts Mandatory Standard on Determination of Migration Amount of BADGE and BFDGE in Food Contact Materials and Articles

On May 14, 2024, the National Health Commission of China opened a public consultation on the draft national food safety standard - determination of migration of bisphenol A diglycidyl ether (BADGE), bisphenol F diglycidyl ether (BFDGE) and their hydroxyl and chlorinated derivatives in food contact materials and articles. Comments are welcome before June 14, 2025.

This brand-new standard is applicable to the determination of the migration amount of the following chemicals in plastics, food contact paints and coatings, and adhesives and other food contact materials and articles, including:

  • BADGE

  • BADGE·2H2O

  • BADGE·H2O

  • BADGE·2HCl

  • BADGE·H2O·HCl

  • BFDGE

  • BADGE·HCl

  • BFDGE·2H2O

  • BFDGE·2HCl

The draft standard can be downloaded here.

Background

China's national food safety standards GB 4806.15-2024 National Food Safety Standard Adhesives for Food Contact Materials and Articles and GB 4806.7-2023 National Food Safety Standard Food Contact Plastic Materials and Articles both give clear restrictive requirements for bisphenol A epoxy derivatives. Among them, the restrictive requirements for bisphenol A diglycidyl ether homopolymer in GB 4806.15-2024 are shown in Table below.

Entry No.

Name

CAS No.

Maximum usage (%)

SML/QM (mg/kg)

SML(T) (mg/kg)

SML(T) Group No.

Other requirements

274

Bisphenol A diglycidyl ether homopolymer

25085-99-8

As necessary

0.05 

(4,4'- dihydroxydiphenylpro

pane/ bisphenol A: SML);


9 mg/6 dm

[in terms of the sum of BADGE, BADGE·H2O and BADGE·2H2O: QM] or 9 [in terms of the sum of BADGE, BADGE·H2O and BADGE·2H2O: SML(T)];


1mg/6dm

[in terms of the sum of BADGE·HCl, BADGE·2HCl and BADGE·H2O·HCl: QM] or 1 [in terms of the sum of BADGE·HCl, BADGE·2HCl and BADGE·H2O·HCl:

SML(T)]

//

It shall not be used in the production of food contact materials and articles intended for infants and young children. 

The SML/QM of the restrictive requirements for other bisphenol A epoxy derivatives is consistent with that of bisphenol A diglycidyl ether homopolymer. The SML/QM of bisphenol A epoxy derivatives in 4806.7-2023 is consistent with GB 4806.15-2024.

In terms of testing method standards, China has not yet established a national standard for testing the migration of epoxy derivatives in food contact materials, and currently has only two industry standards (SN/T 2819-2011 and SN/T 4084-2014). Therefore, the drafting team has fully investigated the relevant regulations and standards for food contact coatings and coated products in foreign countries and regions such as the European Union, South Korea, and Indonesia, and compiled this draft standard to fill the gap in testing method standards in this regard.

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