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China Announces Two Standards for Food Contact Materials

SafeGuardSHardgoodsMay 13, 2024

SG 69/24

China has issued new mandatory food contact material standards for adhesives and solvent residues.

In March 2024, China’s National Health Commission and State Administration for Market Regulation announced the publication of 47 national food safety standards. Among this set were two important standards for food contact materials (FCM) and articles:

  • GB 4806.15-2024 ‘National food safety standard: Adhesives for food contact materials and products’
  • GB 31604.60-2024 ‘National food safety standard: Determination of solvent residues in food contact materials and products’, a standard that details the methodology for analyzing 25 organic solvents in food contact composite materials and products

GB 4806.15-2024 is the nation’s first standard for food contact adhesives. It:

  • Applies to adhesives that are in direct and those that are not in direct contact with food
  • Details the sensory requirements (Table 1)
  • Sets out general chemical specifications (Table 2, see Table A below)
  • Specifies the positive list of 33 substances/starting materials for adhesives in direct contact with food (Appendix A) and 341 substances/starting materials for adhesives in indirect food contact (Appendix B)
  • Permits additives used in adhesives for direct contact with food to be used in adhesives for indirect food contact
  • Requires adhesive products to indicate the product category (adhesives for direct or indirect contact with food) on the label

GB 4806.15-2024 ‘National food safety standard: Adhesives for food contact materials and products’, Table 2 ‘General physical and chemical indicators’ (per standard text)

ItemParameter RequirementStandard
1Overall migration¹≤10 mg/dm², otherwise ≤60 mg/kg for adhesives used in food contact materials and articles for infants and young children GB 31604.8
2Potassium permanganate consumption¹≤10 mg/kgGB 31604.2
3Heavy metals (expressed as lead)¹≤1 mg/kg GB 31604.9
4Total specific migration of primary aromatic amines (PAA)²Not detected (ND)
(Limit of detection = 0.01 mg/kg)
GB 31604.52

¹Applies to adhesive layer in direct contact with food. Adhesive layers that are indirect contact with food are assessed against national standards for safety requirements for the layer that is in direct contact with food

²Applies to adhesives containing aromatic urethanes or other adhesives that may produce PAA. The specific migration for PAA is conducted on finished goods. ND applies to sum of PAA that are not specified in Appendices A or B of GB 4806.15-2024, GB 9685 and related announcements

Table A

The implementation dates for these two standards are summarized in Table B.

StandardDate of publicationEffective date
GB 31604.60-2024 ‘Solvent residues in FCM and products’February 8, 2024August 8, 2024
GB 4806.15-2024 ‘Food contact adhesives’February 8, 2024February 8, 2025

Table B.

SGS has the expertise to help manufacturers and suppliers of FCM achieve compliance with markets around the globe. Our technical experts have extensive experience of testing materials and articles for many markets. We offer the full range of FCM testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Our experience can ensure your products meet the appropriate territorial regulations for food contact materials and help pave the way for compliance. Contact us to know more or visit our website. In the end, it’s only trusted because it’s tested.

© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.

For further information, please contact:

Lielie Li

Lielie Li

Technical Support - Chemical
HingWo Tsang

Dr. Hingwo Tsang

Global Information and Innovation Manager

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