On 25 September 2023, the National Health Commission released 85 new national food safety standards, 17 of which relate to food contact materials; see the list of standard updates. The 17 new FCM national standards comprise 5 material standards (plastics, metals, rubber, composites and printing inks) and 12 test method standards (the GB 31604 series).

Transition periods

The 5 material standards all have a one-year transition period and will officially take effect on 6 September 2024.

Of the 12 test methods, 2 standards (GB 31604.1 and GB 31604.59) have a one-year transition period and will take effect on 6 September 2024. The other 10 standards have a six-month transition period and will take effect on 6 March 2024.

Summary of the 5 material standards

Plastics, GB 4806.7-2023

Scope: plastic materials and articles for food contact, including unvulcanised thermoplastic elastomers and starch-based plastics.

Implementation date: 6 September 2024

Main changes:

(1) The current standards GB 4806.6-2016 and GB 4806.7-2016 are merged.

(2) Aromatic primary amine migration is added to the test items for plastic materials and articles.

(3) For resins, items in GB 4806.6 such as the various extracts, loss on drying and residue on ignition are deleted.

(4) A list of permitted resins is added, together with a table of abbreviations for generic resin classes.

Metals, GB 4806.9-2023

Scope: metal materials and articles for food contact.

Implementation date: 6 September 2024

Main changes:

(1) New test items for impurity elements lead, cadmium, arsenic and mercury are added, with different impurity content requirements for stainless steel, thin steel sheet, aluminium products, other metal substrates and metal coatings.

(2) Migration of heavy metal elements is expanded from the current 5 metals (lead, cadmium, arsenic, chromium and nickel) to 13 (arsenic, cadmium, lead, antimony, aluminium, chromium, cobalt, copper, manganese, molybdenum, nickel, tin and zinc).

(3) Migration testing of reusable articles must be performed three times; for metal materials (other than stainless steel), any single exceedance among the three results means the article fails.

Rubber, GB 4806.11-2023

Scope: rubber materials and articles for food contact, including natural rubber, synthetic rubber and vulcanised thermoplastic elastomers, but excluding silicone rubber.

Implementation date: 6 September 2024

Main changes:

(1) Aromatic primary amine migration, N-nitrosamines and N-nitrosatable substances are added to the test items.

(2) The correction factor does not apply when 50% ethanol is used as the simulant.

(3) The number of tests for potassium permanganate consumption is clarified: for reusable articles the third migration result prevails; if there is evidence that the three migration results do not increase, the first migration result may be used.

(4) Annex A adds base raw materials permitted for rubber materials and articles.

Composites, GB 4806.13-2023

Scope: composite materials and articles for food contact. Composites are food contact materials and articles of two or more layers made of different or the same materials combined by adhesion, hot melting or other means.

Implementation date: 6 September 2024

Main changes: GB 4806.13 differs considerably from the GB 9683-1988 it replaces, and also from the earlier draft for composites.

(1) Overall, composites shall comply with the food safety national standards for each layer material.

(2) The sensory and general physicochemical indices of the finished article (overall migration, potassium permanganate consumption, heavy metals as Pb, and decolourisation) shall meet the corresponding requirements for the layer in direct contact with food.

(3) Specific migration and residual content must take account of the requirements for each layer material.

(4) Composites and articles intended for direct food contact and used without washing shall meet the microbiological requirements of GB 14934.

(5) For labelling, composite materials shall be indicated in order from the outer layer to the food contact layer, separated by a slash.

Printing inks, GB 4806.14-2023

Scope: inks for food contact materials and articles and the printed ink layers they form, including inks for direct food contact and for indirect food contact, as well as the varnishes used with them.

Implementation date: 6 September 2024

Main changes: the ink standard is newly developed.

(1) Inks need to consider the requirements for formulation raw materials: base materials and additives used in direct food contact inks shall be substances in GB 2760 and the relevant announcements. Inks for indirect food contact shall not use colorants based on lead, mercury, cadmium, chromium (VI), arsenic, antimony or selenium or their compounds, and the colorants used shall meet the requirements of GB 9685; other base materials shall be base materials approved in China for food contact materials.

(2) Test items for inks include sensory properties and soaking solution, residual content of lead, mercury, cadmium, chromium and arsenic, overall migration, potassium permanganate consumption, heavy metals (as Pb) and aromatic primary amine migration.

(3) Labelling requirements for inks: indicate the product category (ink for direct food contact, ink for indirect food contact) and state the printing substrates suitable for use, the printing process (such as curing time) and any special use requirements.

List of FCM standard updates