China Releases GB 4806.15-2024 Adhesives for Food Contact Materials and Articles

On March 12, 2024, China National Health Commission announced the promulgation of GB 4806.15-2024 National Food Safety Standard Adhesives for Food Contact Materials and Articles. This new standard specifies the terms and definitions, product classification, basic requirements, technical specifications, labeling, etc. of adhesives used in food contact materials and articles. It will enter into force on February 8, 2025.

As per the standard, adhesives for food contact are classified into two types according to whether they are in direct contact with food:

Adhesive in direct contact with food: adhesives used on the food contact surfaces of food contact materials and articles, which are expected to be in direct contact with food, such as pressure-sensitive adhesives used for fruit stickers.

Adhesive in indirect contact with food: adhesives used on the non-food contact surfaces of food contact materials and article, which are not expected to be in direct contact with food but whose components may migrate into food, such as adhesives used among layers of composite materials.

The following are the key requirements for these adhesive products.

Ingredients

The ingredients used for these two types of adhesives are subject to different requirements. Considering the comparatively higher safety risks, adhesive directly contact with food can only contain basic raw materials listed in Appendix A of GB 4806.15-2024 (51 items) and relevant announcements. However, for adhesive indirectly contact with food, substances included in Appendix A, Appendix B (341 items) and relevant announcements are all applicable. The use of additives should follow the requirements specified in GB 9685 Standard for Uses of Additives in Food Contact Materials and Articles and related announcements. It is noteworthy that the additives permitted in adhesive directly contact with food can be used in adhesive indirectly contact with food as well.

Physiochemical indicators

Considering that Primary aromatic amines (PAA) may be produced during the curing reaction of aromatic polyurethane adhesives, epoxy adhesives using amine curing agents, polyimide adhesives, etc., the new standard sets the migration amount limits of PAA in relevant adhesives. Additionally, the detection test of PAA migration should be carried out after the completion of the adhesive’s curing reaction.

The overall migration limits for adhesives used in food contact materials and articles specialized for infant and young children should be converted from mg/dm² to mg/kg as per the area-volume ratio in actual use. The maximum migration level of such adhesive is 60 mg/kg.

Labeling

In addition to conforming to the requirements in GB 4806.1-2016 General Safety Requirements for Food Contact Materials and Articles, the adhesive products should be labeled with the product type, that is, “adhesive in direct contact with food” or “adhesive in indirect contact with food”.