On October 15, 2020, the Chinese National Health Commission (NHC) published a set of five draft national food safety standards related to the manufacture and use of food contact materials (FCMs). In a summary article, law firm Keller and Heckman provides an overview of the main components within each. The five draft standards cover (i) composite materials and articles, (ii) printing inks, (iii) paper and paperboard, (iv) bamboo and wood materials and articles, and (v) detergents.

For composite materials and articles, the draft defines standards that must be adhered to for overall migration, heavy metals, and de-coloration tests. It further specifically notes that the label of such materials must identify the type of material used within each layer. For the printing inks standard, no positive list has been created, but it does set requirements for the raw materials used.

The paper and paperboard standard keeps many of the previously existing requirements, but removes limits on potassium permanganate consumption and heavy metals as well as adds residual limits on 1,3-dichloro-2-propanol (CAS 96-23-1) and 3-chloro-1,2-propanediol (CAS 96-24-2). The standard on the use of materials and articles made from bamboo and wood is reported to have revised various physicochemical specifications, including lowering microorganism residual limits.

The standard on food contact detergents categorizes substances into two classes: “Class A detergents are those used directly for washing food, whereas Class B are those used to wash food-contact utensils, tools, equipment, food packaging materials, and containers, etc.” For Class A detergents, a new positive list of permitted raw materials has been included. Preservatives and colorants used in Class B detergents must be included among the positive list for Class A detergents. In order to use any other substances which are not included in the Class A list in Class B detergents, the manufacturer “must conduct a safety assessment to make sure the residual or migration level of these substances may not endanger human health.”

The draft standards are open for public comment until November 30, 2020.

Read More

Keller and Heckman LLP (October 19, 2020). “Breaking News: China Announces Draft GB Standards Related to Food Contact Materials & Articles.”


National Health Commission (October 19, 2020). “Letter from the Secretariat of the National Food Safety Standards Review Committee on soliciting opinions on 18 national food safety standards (draft for comments) including gum bases and ingredients.” (in Chinese)