The framework legislation GB 4806.1-2016 and the positive list for additives GB 9685-2016 for materials and articles which come into contact with food in China both applied on October 19. Which indicates that the identification tag, declaration of conformity, and also additives, need to meet the new requirements.

Articles, failed to comply with new GB standards will be returned or destroyed

since certain specific products standards regarding plastic, plastic resin, paper, metal, rubber, coating, glass, enamel, and ceramic entered into force since Apr 19th, many imported products failed to comply with the new GB standards and to be returned or destroyed. As data shows, General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China (AQSIQ) totally notified 23 batches of food contact articles violations from April to August of 2017. Over one-third are rubber nipples containing exceeding volatile compounds, while plastic tableware is notified, mostly because of acrylonitrile and decolorization test. Dissolve of heavy metal lead usually gets overlooked in glass and ceramic ware. Besides, lacking Chinese labeling is a long-lived issue. Those unqualified food contact articles mainly come from Britain and Japan.

In addition, 21% of recalled imported consumer products are food contact articles during the past four months.

Many guidance and technical documents offer assistance

The chapter 8 of GB 4806.1 states the content, location and display of label. Differ from the old one, new legislation GB requests a declaration of conformity (DoC), and words “Food Contact Use”, or “Food Contact packaging” also required. Moreover, there may be some difficulty on how to validly label materials name of products, especially products with various materials. The Guidelines for Food Contact Household Appliance Identification and Labeling will provide with necessary instruction.

The industrial guideline for obligation to supply chain and declaration of conformity for plastic food contact materials clarifies all roles’ obligations and responsibilities throughout the supply chain, the certain information demands for Declaration of Conformity (DoC) of chemical substances, intermediate materials and final product. Templates of declaration are also attached.

European legislation designates authorised monomers or other starting substances while New Chinese GB standards regulate directly the polymers. Enterprises need to firstly whether the additive is authorised by GB 9685-2016 or GB 2760, otherwise, apply for permission before use. The authorised uses of additives Confirm the conditions of authorised additives, including maximum use, specific migration limit (SML) and other restrictions must be acknowledged. Elements test, compliance assessment and declaration of conformity are important. GB 9685-2016 National Food Safety Standards: implementation guidelines for Standards for Uses of Additives in Food Contact Materials and Articles can be a great reference.

Supply chain communication and information exchange are the key points.

Whether selecting high-quality raw materials, or manufacture according to GMP, or issuing the DoC, transfer and exchange of information in supply chains always required. The new GB standards of FCM will accelerate supply chains resource redistribution, eliminate the redundant work, and release the enterprises’ burdens.

The requirements remain changing

So far, Chinese standards for ink, adhesive, laminated materials, starch-based plastics, and wood, bamboo and cork used in food containers and packaging materials are all on schedule. The food contact laminated materials and wood, bamboo and cork draft standards have been released for a while. And National Health and Family Planning Commission (NHFPC) consulted for intending to formulate cellophane standard, and revise the current metal, plastic, paper and paperboard, also general regulation of migration test standard.

It is said that the adhesive, laminated materials and wood, bamboo and cork standards will be published in May next year.