In an article published on February 24, 2017 by regulatory news provider Chemical Watch, editor Sunny Lee discussed the implications of China’s new food packaging regulations for U.S. or EU importers. Updates to Chinese legislation on food contact materials (FCMs) were announced in November 2016 and will take effect on October 19, 2017 (FPF reported).

Mark Thompson of the law firm Keller and Heckman, speaking at a webinar organized by Chemical Watch, said that “the clearances for FCMs in China are – in many cases – ‘very different’ from the substances approved in the EU.” For example, while the regulation (EU) No 10/2011 on plastics contains a list of approved starting substances that can be used to produce polymers, the Chinese lists contain both monomers and polymers. Furthermore, polymeric materials can be regulated under several standards in China, including that on plastic resins, plastic materials and articles, coatings and coatings layers, and rubber materials and articles. The introduction of a new type of packaging or FCM in China will require obtaining a pre-market approval from the authorities.

Speaking about specific substances that are authorized in the EU, but not in China, Mr. Thompson explicitly mentioned four phthalates (die-2-ethylhexyl phthalate (DEHP, CAS 117-81-7), dibutyl phthalate (DBP, CAS 84-74-2); diisobutyl phthalate (DiBP, CAS 84-69-5), and benzyl butyl phthalate (BBP, CAS 85-68-7), as well as perfluorooctanoic acid (PFOA, CAS 335-67-1).

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Sunny Lee (February 24, 2017). “China’s food packaging rules present unique challenges.Chemical Watch

Smithers Pira (March 2017). “China develops food packaging standards.