SAFEGUARDS| Hardgoods NO. 185/15

The new Chinese regulations on food contact materials (FCM) is expected to be published in early 2016. Multiple draft regulations have recently been released [1] for public consultation on the 29th of September, 2015. The consultation period is one month. This Safeguard covers the requirements for metallic food contact materials and articles.

This new regulation will eventually supersede all the previous regulations on metallic material and articles (i.e. GB 9684, GB 11333). The technical requirements are split into two parts: material and article.


The regulation specifically demands the composition of materials shall match with its claimed type. On one hand, this minimizes the market deceit. On the other hand, this creates certain barriers to the innovation of metallic materials.

Other requirements are listed below.

Composition of alloy, constituents


Metallic material and metal substrate

Lead (Pb), Cadmium (Cd), Arsenic (As), Mercury (Hg), Beryllium (Be), and Lithium (Li) are prohibited

As ≤ 0.01 %(m/m)

Cd+Pb ≤ 0.01 %(m/m)

Metallic plating (the plating only)

Pb, Cd, Cyanide (CN-), and hexavalent Chromium (Cr(VI)) are prohibited

As ≤ 0.01 %(m/m)

Cd+Pb+Hg ≤ 0.01 %(m/m)

Soldering material(the solder only)

Cd ≤ 0.01 %(m/m)

Pb ≤ 0.1 %(m/m)

Pb is a common element coexisting in natural iron ore. Although this requirement poses certain amounts of pressure on iron products (cast iron grill, iron wok, etc), it will help to mitigate the exposure to these toxic substances in the long run.


The requirements on articles include two categories: sensory and migration.

The FCM article shall not bring deterioration to the organoleptic properties of the food. The material itself shall pass inspection (e.g. no crack, no rust).

The migration limits are listed below.


Specific Migration Limit (mg/kg food)


(if the element is not part of the stated material composition, no need to verify its SML)


(every element must be tested regardless of the materials’s  compostion)

Arsenic (As)


Cadmium (Cd)


Lead (Pb)


Aluminum (Al)


Chromium (Cr)


Nickel (Ni)


Tin (Sn)

100 (see note)

Antimony (Sb)


Zinc (Zn)


Note: the SML of Sn shall respect GB 2762 (maximum contamination in food) for tin plated container.

The migration test is similar to Council of Europe’s metal guideline, “Metals and alloys used in food contact materials and articles: A practical guide for manufacturers and regulators” (EDQM). [2] If the product is placed in contact with acidic food, 5g/L citric acid is applied as the stimulant. If not, artificial tap water is applied. The draft also listed a short table exemplifying the test condition for typical products. It is worth noting that, for electric and electronic kitchenware, actual use (product manual) condition can be used for testing.

Additional limitation

Uncoated aluminium and aluminium alloy, copper and its alloy, plated metal are prohibited to be placed in contact with acidic food. Based on survey results, these metals show the highest migration among all metal types.

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. From overall migration test to expert advices on emerging regulations and compliance issues and documentation review, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Dr. Samuel Lee
Global Competence Support Centre Food Contact Material committee
t: + 8620 3213 6200

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