Latest Regulation Updates of Food Contact Materials in China

China’s competent food safety authorities are optimizing China’s existing FCM regulatory framework. Some new product standards will be drafted to account for previously overlooked areas, such as inks, adhesives and regenerated cellulose standards Currently the delivery of DoC throughout the supply chain is one of the biggest regulatory compliance challenges.

During the CRAC summit held by REACH24H consulting group from Sep. 9 to 12, 2018, Shang Guiqin, director of State Food Contact Materials Testing Key Laboratory, delivered a keynote speech related to China’s food contact materials’ regulation system and its latest regulation development.

Food contact material and articles (FCM) are regulated comprehensively in China, throughout product lifecycle and the associated supply chains. FCM ingredients are subject to a positive list system which is based on an inventory of permitted FCM ingredients. During production, upstream manufacturers are required to deliver the DoC (declaration of compliance) to downstream companies.

In 2016 China NHFPC unveiled 53 FCM national food safety standards, establishing a new regulation system. However in recent years there have been some issues associated with the implementation of those new GB standards, including:

Existing standards do not cover all products
Some common additives are not included in the positive list
Some requirements are ambiguous or contradictory.
The migration test standards do not align with the general standard
DoC delivery throughout the whole supply chain is difficult as it has the potential to undermine enterprise proprietary information

The competent authority has already taken a series of initiatives to deal with those problems. In 2018, NHC finished public consultation on some GB standards for composite materials and products, starch-based plastic materials and products. Currently the authority is drafting inks, adhesives and regenerated cellulose product standards as well as revising the following standards:

In 2019, GB standards listed below are proposed to be amended/drafted

Shang Guiqin revealed that the permitted list of rubber polymer may be expanded in future, and some detailed items, such as applicability of 5% alcohol, will be adjusted as well.