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New Regulations for Food Contact Materials in China

New regulations for the use of paper, bamboo and wood in Food Contact Materials for the Chinese Market

Some changes are coming up in China´s regulations in Food Contact Materials (FCM). China has established a regulatory and standard framework for FCM and products, including general standards (GB 4806.1 and GB 9685), product standards (GB 4806.2-12), testing standards (GB5009.156 and GB 31604) and production specifications (GB 31603). There are also requirements outlined in the regulations for “declaration of conformity” (DoC) and labeling for FCM.
On July 28, 2022, “Nation Health Commission of the People's Republic of China” (NHC) published two important standards for paper, bamboo, and wood FCM to add to the current FCM regulatory framework.

GB 4806.8 - 2022 National Food Safety Standards: Food contact paper, paperboard and its products
GB 4806.8 was first issued in 2016, and this release is a revised version. Key points of the revision are summarized as below:
• Removal of the potassium permanganate consumption indicator
• Added a requirement for residual of substances of high concern to the industry for 1,3-dichloro-2-propanol (1,3-DCP) and 3-chloro-1,2-propanediol content (3-MPCD) residue indicators and corresponding testing method
• Refined the management requirements and testing procedures for food contact paper
The official implementation date of this standard is June 30, 2023. Before the official implementation, companies can choose to implement the original version or the revised version. However, after June 30, 2023, the old national standards will be invalid, and the new standard will be mandatory.

GB 4806.12 - 2022 National Food Safety Standards: Food contact bamboo and wood materials and products
This is the first time China has issued mandatory standards for bamboo and wood products. GB 4806.12 provides a scientific basis for compliance of bamboo and wood FCM in China. This standard is divided into sections including:
• Technical requirements: including sensory requirements, physical and chemical indicators and microbial limits. Among the physical and chemical indicators, migration indicators and residue indicators are included
• Migration test requirements
• Labeling requirements
The implementation date of this standard is December 30, 2022. It is recommended that in the next four months companies should align with the new standard in a timely manner, and reduce the risk of non-compliance.

To ensure that your Food Contact Materials meet China’s regulatory requirements, please contact the knoell FFCM team via FFCM@knoell.com or find more insight on Food Contact Material.