53 national food safety standards for food contact materials and articles were issued in Nov. 2016 and came into effect a year later. There is a clear correlation between the promulgation of these new standards and a significant reduction in inward trade both in volume and value terms. Shenzhen customs data (Oct 19, 2017 to Feb 26, 2018) shows that imports of food contact plastic materials amounted to 167 batches (down 45% YOY), representing a value of $1.45 million (down 53% YOY), likely attributable to the promulgation and enforcement of the new FCM standard GB 4806.1-2016. (See FCM standards and regulation system here)
New requirements
The new national standards impose both new and more stringent requirements including migration limits, basic requirements, principles of compliance, test methods, traceability, product information etc. For example, the following two documents are required for imports of food contact plastics:
Declaration of compliance that includes facts about ingredients, food additives, overall migration compliance, restricted substances and so forth.
Report of overall migration amount issued by organizations/laboratories recognized by China National Accreditation Service for Conformity Assessment (CNAS).
Other documents are required also, but the two listed above are core problem for importers.
New challenges that enterprises confront
Difficulty obtaining ingredient and additive information:
Most importers of FCM buy products from overseas traders instead of manufacturers. Generally speaking FCM traders know little about product composition in terms of ingredients or additives and this is often compounded by manufacturers actively protecting proprietary information relating to product development, manufacturing, processing etc.
Failure to make timely submission of acceptable migration data reports:
FCM are generally imported with a migration data report issued by overseas laboratories which are not accredited by Chinese authorities and therefore invalid. China’s FCM regulations stipulate a limited number of accredited testing laboratories which can generate data acceptable by CNAS.
Tips
Learn new regulations and new requirements that involve your products
Find a qualified laboratory to generate FCM migration data and report by deadline
Reinforce communication in the supply chain and ascertain FCM ingredient and additive content
Recommended reading
China Food Contact Materials Regulation
An Analysis of China New Food Contact Material Substances in 2017
GB 4806.1-2016 General Safety Requirements for Food Contact Materials and Articles
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