China's NHC Released New Standard for Food Contact Ink and 16 Other FCM National Standards - Industry News - C&K Testing

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On September 25, 2023, the National Health Commission (NHC) released announcement No. 6, 2023 regarding 85 national food safety standards, including National Food Safety Standard - Tea (GB 31608-2023), along with three modification documents.

Among these standards,17are related to food contact materials, includingfivefor food contact materials products standards,twogeneral principles, andteninspection methods.Of particular importance is the introduction of a new food contact ink standard. Additionally, revisions have been made to existing standards pertaining to food-contact plastics, metals, rubber, and composite materials. These updates further clarify the management principles and requirements and the approved use of fundamental materials, aiming to bolster food safety, ensure consumers’ well-being, and address practical industry concerns.

Specific regulations are as follows:

Standards for food contact materials and products

Standard Number	Standard Name	Date of Implementation	Substitute Standard
GB 4806.7-2023	National Food Safety Standard - Food Contact Plastics	2024.9.6	GB 4806.6-2016, GB 4806.7-2016, and plastic resins recorded in relevant announcements issued by NHC (former NHFPC)
GB 4806.9-2023	National Food Safety Standard - Food Contact Metals		GB 4806.9-2016
GB 4806.11-2023	National Food Safety Standard - Food Contact Rubber		GB 4806.11-2016 and rubber basic raw materials recorded in relevant announcements issued by NHC (former NHFPC)
GB 4806.13-2023	National Food Safety Standard - Food Contact Composite Materials		GB 9683-1988
GB 4806.14-2023	National Food Safety Standard - Food Contact Ink		New standard

General principles for food contact materials and products

Standard Number	Standard Name	Date of Implementation	Substitute Standard
GB 31604.1-2023	National Food Safety Standard - General Principles for Food Contact Materials Migration Tests	2024.9.6	GB 31604.1-2015
GB 31604.59-2023	National Food Safety Standard - General Principles for Validation of Chemical Analysis Methods for Food Contact Materials and Products	2024.9.6	New standard

Standards for inspection methods of food contact materials and products

Standard Number	Standard Name	Date of Implementation	Substitute Standard
GB 31604.7-2023	National Food Safety Standard - Food Contact Materials and Products Decoloration Tests	2024.3.6	GB 31604.7-2016
GB 31604.29-2023	National Food Safety Standard - Determination of Migration of Food Contact Acrylic Acid, Methacrylic Acid, and Their Esters		GB 31604.29-2016
GB 31604.46-2023	National Food Safety Standard - Determination of Food Contact Free Phenol and Migration of Phenolic Compounds		GB 31604.46-2016
GB 31604.47-2023	National Food Safety Standard - Determination of Food Contact Paper, Paperboard, and Fluorescent Substances in Paper Products		GB 31604.47-2016
GB 31604.49-2023	National Food Safety Standard - Determination of Food Contact Multielements and Multielement Migration		GB 31604.49-2016
GB 31604.54-2023	National Food Safety Standard - Determination of Food Contact Bisphenol F and Bisphenol S Migration		New standard
GB 31604.55-2023	National Food Safety Standard - Determination of Food Contact Isothiazolinone Compounds Migration
GB 31604.56-2023	National Food Safety Standard - Determination of Food Contact Lauramide Migration
GB 31604.57-2023	National Food Safety Standard - Determination of Food Contact Benzophenone-type Substances Migration
GB 31604.58-2023	National Food Safety Standard - Determination of 9 Food Contact Antioxidants Migration

Major changes in the five updated standards for food contact materials and products

GB 4806.7-2023 National Food Safety Standard - Food Contact Plastics

Revised National Food Safety Standard - Food Contact Plastic Resins (GB 4806.6-2016) and National Food Safety Standard - Food Contact Plastics (GB 4806.7-2016);
Incorporated relevant safety requirements for food contact starch-based plastics;
Specified the guidelines for managing plant fiber fillers. Plant fiber fillers are categorized as food contact additives, and must comply with the requirements of the National Food Safety Standard - Food Contact Additives (GB 9685);
Added usage limits on primary aromatic amines (PAAs); and
Updated the list, usage limits, and requirements for plastic resins. Specific principles have been provided regarding the use of sodium salts, potassium salts, and calcium salts (including acid salts and complex salts) when the monomers or other initiators used in resin synthesis are acids, alcohols, or phenols.

GB 4806.9-2023 National Food Safety Standard - Food Contact Metals

Increased migration limit indicators for alloy elements; revised specific requirements for migration tests (Appendix A), specifying the required number of migration tests for metals and products expected to be reused; removed specific using requirements;
Added fundamental requirements for metal surface treatment processes;
Introduced requirements for alloy and impurity elements in metal substrates and metal coatings;
Removed provisions regarding the shape and use of stainless steel materials;
Standardized migration limits for impurity and alloy elements in various metal materials and products; and
Unified the selection requirements for food simulants and migration test conditions for various metals, specifying the number of migration tests required for stainless steel and other metal products intended for repeated use.

GB 4806.11-2023 National Food Safety Standard - Food Contact Rubber

The standard applies only to rubber materials and products, while silicone rubber has been removed and will be managed by other standards;
Added total migration limits for primary aromatic amines (PAAs) and N-nitrosamines and N-nitrosatable substances, respectively, and specified the scope of application for these two indicators;
Clarified specific testing requirements for rubber materials and products intended for repeated use during the potassium permanganate consumption test;
Modified the requirements for oil-based food simulants; and
Updated the list and usage requirements of basic raw materials permitted for rubber materials and products. Clarified the usage principles of sodium salts, potassium salts, and calcium salts (including acid salts and double salts) when the monomers or other starting materials used in resin synthesis are acids, alcohols, or phenols.

GB 4806.13-2023 National Food Safety Standard - Food Contact Composite Materials

Expanded the scope of application to include all food contact composite materials and products;
Removed specific provisions regarding physicochemical indicators in the original standard, retaining only the general requirements. Final products of composite materials and products should meet the general physicochemical indicators and other specific requirements based on the materials and structures involved;
Specified microbial limit requirements for composite materials and products expected to come into direct contact with food without undergoing disinfection or cleaning; these should comply with the provisions of National Food Safety Standard - Disinfection Utensils for Food (GB 14934); and
Labeling should first comply with the requirements of National Food Safety Standard - General Safety Requirements for Food Contact Materials and Products (GB 4806.1); it should also indicate in the order from the outermost layer to the layer directly in contact with food, including adhesives, coatings, and inks, are separated by a slash “/” symbol.

GB 31604.1-2023 National Food Safety Standard - General Principles for Food Contact Materials Migration Tests

Added migration test requirements for multi-material food contact materials;
Optimized the selection principles for food simulants;
Optimized the selection principles for migration test conditions;
Improved the requirements for correcting migration test results;
Added requirements for selecting migration test results; and
Adjusted Appendix A.

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