On 12 December 2016, the Industry Guideline on Plastic Food Contact Materials regards as Responsibilities along the Supply Chain and Document of Compliance (DoC) (Download the Chinese Version) prepared by Food Contact Materials Panel Commission under China Food Industry Association seeks for opinions on the official website. The consultation period closes on 10 January 2017.

The “Document of Compliance” (DoC) is initially introduced in Chinese regulatory framework on food contact materials as an integral part of product identification inGB 4806.1-2016 National Food Safety Standard- General safety requirements of food contact materials and articles published on 18 November 2016. The DoC requirements will be enforced since the entry into operation of the standard on 19 October 2017.

Pursuant to Chapter 8 of the standard GB 4806.1-2016:

8.3 Identification contents shall include product name, material, Document of Compliance (DoC) of relevant regulations and standards, names, addresses and contacts of manufacturers and (or) distributors, production date and shelf life (if applicable),etc.

8.4 The Document of Compliance (DoC) shall include regulations and standards the products comply with, and their compliance with restrictions (specify the restricted substances and threshold limits) and overall migration (limited to finished products).

The guideline clarifies responsibilities of all characters along the supply chain, elements and reference formats of Document of Compliance (DoC).

(Below is the procedure throughout the supply chain of food contact plastic materials)

It also details the DoC requirements for the aforesaid manufacturers (chemicals, intermediate materials and end products) and distributors.

Meanwhile, supporting documents are necessary to prove the compliance of restrictions specified in DoC, including but not limited to:

• Notes to quality and spec. of raw & auxiliary materials;
• Compliance screening, test or assessment reports for the restricted use under regulations/standards;
• Other evaluation materials with regard to safety of food contact materials.

It should be noted manufacturer is the entity of DoC and the documents shall be promptly updated in case any change to regulation/standard or to constituent or purity of substances/materials. The DoC will be a priority for enforcement upon the entry into operation of GB 4806.1-2016. C&K Testing advises manufacturers shall pay great attention and send the products for testing to confirm compliance.

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