The Government of China is updating the General Safety Requirements for Food Contact Materials and Articles (GB 4806.1), which is the primary legislation for the regulation of food contact materials (FCMs) in the country. Additionally, in recent weeks, new substances have been added to the positive list for FCMs and the allowed uses of other substances was expanded.
FCM regulation amendments
According to reporting from Chemical Watch, the National Center for Food Safety Risk Assessment (CFSA) “plans to expand the scope” of GB 4806.1 to incorporate polymers, broader uses of previously approved materials, as well as food ingredients. In the update, plastics, rubber, silica gel, paints, adhesives, and oil paints, that already have CFSA approval could be blended for use in FCMs, provided no chemical reactions occur. This revision also permits substances approved as food ingredients, like preservatives, to be utilized in FCM manufacturing, contingent on meeting GB 4806.1 requirements. Other amendments define the terms ‘complete barrier layer’, redefine ‘effective barrier layer’, and explicitly exclude outer packaging or material from the ‘food contact material’ definition unless it directly contacts food.
Voluntary industry standards
Website Packaging Law reports that the China National Food Industry Association published two new voluntary standards in February 2023 that build on top of the regulations included in GB 4806.1. China’s national FCM standard includes general regulations, but when writing a Declaration of Compliance companies may need more guidance. The two voluntary industry standards cover declarations for FCMs/FCAs and adhesives, T/CNFIA 162-2022, and T/CNFIA 163-2022, respectively. The association plans to develop a voluntary standard for printing inks as well.
New substances – (CAS, relevant material)
CFSA and the China National Health Commission have also recently concluded studies and consultations on several new food contact chemicals:
- Tricyclodecanedimethanol polymer with terephthalic acid and 1,6-hexandiol (resin for coating)
- Fatty acids, C18-unsaturated, dimmers, hydrogenated polymers with 1,4-butanediol, ethylene glycol, terephthalic acid and trimethylolpropane, block (PET) – (plastics)
- 1,6-hexanedioic acid, polymer with (E)-2-butenedioic acid and tricyclodecanedimethanol – (coatings)
- Polymer of 1,4-butanediol, 2,2-dimethyl-1,3-propanediol, 1,4-cyclohexanedicarboxylic acid and m-phthalic acid – (coatings)
- Polymer of butanediol-1,4, tricyclodecanedimethanol and dimethyl terephthalate – (coatings)
- Carbon black — (CAS 1333-86-4, PEEK plastics)
- Acrylamide, 2-methacryloxyethyltrimethyl ammonium chloride, itaconic acid, and N,N’ -methylenebis acrylamide – (CAS 214495-32-6, paper and board)
- 2-acetoxy-1,2,3-propanetricarboxylicacid tributylester – (CAS 77-90-7, ink)
- Polymer from 1,4-terephthalic acid and sebacic acid and 1,2-ethylene glycol – (CAS 25067-21-4, resin for PET film)
- 2-propenoic acid, 2-methyl-, polymer with butyl 2-methyl-2-propenoate, ethyl 2-propenoate and methyl 2-methyl-2-propenoate, salts with 1,4-benzenediol-epichlorohydrin-4,4′-methy lenebis[2,6-dimethylphenol]polymer-2-(dim methylamino)ethanol reaction products – (paints, coatings)
References
CFSA (April 19, 2023). “National Center for Food Safety Risk Assessment on Solicitation for “National Food Safety Standard General Safety Requirements for Food Contact Materials and Products” (GB 4806.1) letter of opinion.” (in Chinese)
Packaging Law (April 19, 2023). “China industry association issues voluntary standards for DoC for FCMs.” PackagingLaw.com
Jerry Wang (April 21, 2023). “China to Amend GB 4806.1 General Safety Requirements for Food Contact Materials and Articles.” ChemLinked
Girija Shettar (April 24, 2023). “China consults on expanding the scope of substances allowed for use in FCMs.” ChemicalWatch
CFSA (April 25, 2023). “Regarding the public solicitation of opinions on new varieties of 5 food-related products including CI Pigment Black 7.” (in Chinese)
Packaging Law (May 2, 2023). “China Solicits Comments on Five Food-Contact Materials.” PackagingLaw.com
Jerry Wang (May 8, 2023). “[Updated] China Food Contact Materials in 2023: NHC Newly Approves One FCM Additive and Five Resins.” ChemLinked
Girija Shettar (May 9, 2023). “China consults on five substances approved for use in FCMs.” ChemicalWatch
Jerry Wang (May 16, 2023). “China Publishes the Updated Catalogue of New Food Raw Materials, Food Additives, Food Contact Materials and Their Applicable Standards.” ChemLinked
Girija Shettar (May 12, 2023). “China’s health commission approves six substances for use in FCMs.” ChemicalWatch
