In an article published July 29, 2021, law firm Keller and Heckman summarizes China’s recent approval of ten new food contact materials (FCMs), chemicals, and resins for use in food contact, as well as the expanded usage of nine others. Of those newly approved, two are chemicals for use in paper and board and the third is a polymer. The polymer is poly(1,4-butylene adipate) (PBA, CAS 25103-87-1), which is a biodegradable polyester and a substance of potential concern according to the Food Packaging Forum’s Food Contact Chemicals database. China’s approval of it stipulates that the polymer is for use in plastics at “a maximum use level of 0.09% and a specific migration limit (SML) of 5 mg/kg (1,4-butanediol)” and is to never come in contact with baby food or breast milk. Two of the 9 materials approved for expanded usage are also in the FCCdb.  

Zinc phosphate (CAS 7779-90-0), which is now approved by the Chinese authoritiesfor use in coatings and coating layers at a maximum use level of 12% (based on the dry weight of film) and with an SML of 25 mg/kg (as zinc),” is a priority hazardous substance on the FCCdb due to being listed within the globally harmonized system for classification and labeling of chemicals as an environmental hazard. Another of the newly approved substances, 2-amino-ethanol (CAS 141-43-5), is used in paper and board FCMs and is included in the FCCdb as a substance of potential concern for its putative endocrine disrupting properties. China’s expanded regulation states that paper and board materials containing 2-amino-ethanol canonly contact fatty foods when filling at room temperature and long-term storage at room temperatureand cannot contact baby food or breast milk.  


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Keller & Heckman (July 29, 2021). “China Approves New Food-Contact Materials.” Packaging Law