In an article published on March 21, 2019, law firm Keller and Heckman LLP (KH) discussed changes that took place within China’s regulatory system in the year 2018 that affect the food packaging industry within the country. KH reported earlier in March 2018 on a “massive” restructuring of China’s organizational bodies that affected food regulatory agencies. This most recent article now reports that since “the reshuffle is fully in place at the central level, [KH] expect[s] to see a continuous roll-out of regulations and standards in 2019 to accommodate the restructured food regulatory system.”

Specifically, regarding food packaging, KH summarized a number of important developments that took place during 2018 including:

  • The publication of the guidance book “Implementation Guidance on Migration Testing Standards for Food Contact Materials and Articles,” which provides “comprehensive and practical interpretations and guidance” for implementing Chinese regulations GB 31604.1-2015 on migration testing of food contact materials (FCMs) and articles and GB 009.156-2016 on pre-treatment methods in migration testing of FCMs and articles.
  • The publication of the “General Rules for the Implementation of Production Licensing for Industrial Products,” which includes “product-specific detailed implementation rules” that apply to food packaging materials.
  • Generally increased supervision of food contact materials within the country. The article references the example of a heavy fine recently placed on a juice vending machine manufacturer that was found to use a non-compliant food contact metal in their machines.

Read more

Keller and Heckman LLP (March 21, 2019). “From The Year of the Dog to The Year of the Pig: China’s Food and Food Packaging Laws Year-in-Review.”