Global Legal Compliance Strategies for Packaging Materials | China

China has completely revised the food contact legislation since 2015.

Requirements on food contact materials and articles are nowadays based on the national GB standards (Chinese: Guobiao) 4806 series. Part 1 defines the fundamental requirements comparable to the European Framework Regulation while subsequent parts of GB 4806 series cover specific materials like plastics, paper, metals or rubber.

GB 9685 from 2016 contains an exhaustive list of additives and monomers which are approved to be used in different types of food contact materials. Restrictions laid down in GB 9685 are widely identical to the limits in the European Plastic Regulation but there are also differences.

In addition additives might be approved only for specific materials like plastics, paper or lacquers and coatings. A careful legal assessment is, therefore, recommended to comply with:

Food safety law of the people’s Republic of China

• Prohibits import, use or purchase of food-related products (e.g. food additive, food packaging materials) not in compliance with the applicable Chinese Food Safety Standards

Standard GB 31603-2015

• General hygiene principles on the manufacturing of food contact materials and products

Standard GB 9685-2016

• Positive list of food contact material additives for different materials
• List of specific migration limits and approved applications

Standard GB 4806-2016 series

• 4806-01: General Safety Requirements
• ...