SAFEGUARDS | Hardgoods NO. 188/15

SafeGuardS slice set

On the 29th of September 2015, the National Health and Family Planning Commission of the People's Republic of China (NHFPC) released draft GB standards for food contact plastic resins and articles. [1] The public consultation lasted 1 month. Now the legislators are making the last round of modifications and the final version is expected early 2016.

For both plastic resins and articles, the following requirements must be complied with. For the resin manufacturers, to verify the regulatory status of the products, test pieces (film or board) must be prepared. The guideline on how to craft such test samples will be provided in a Q&A currently under preparation.




Overall migration

test condition depending on its usage

10 mg/dm2

or 60 mg/kg stimulant if in contact with food for infants and children

Consumption of potassium permanganate 
distilled water, 60 ℃ for 2hr

12 mg/kg stimulant

Migration of heavy metal (as lead)
4% (v/v) acetic acid, 60 ℃ for 2hr

1.2 mg/kg stimulant

Color release


Compared with the previous Chinese regulation on plastic, overall migration (OM) replaced the evaporation residual but the other parameters are preserved. Except for overall migration, where test condition varies depending on the actual usage of the articles, other parameters have fixed test condition. The limit of OM is the same as European Regulation (EU) No. 10/2011. The limit of other parameters remain the same (since the default migration ratio has been changed from 1 cm2/2 ml to 6 dm2/1 L, the limits are adjusted accordingly).

In the meantime, GB 9685, the regulation on additives (additives and starting materials are both covered in this "additive" regulation) shall be complied too. That is, the specific migration, composition and usage of a substance must satisfy the requirement stated in GB 9685.

It is worth noting that thermoplastic elastomers (TPE) are classified as plastic. No further discrimination based on the vulcanization status is needed. Nevertheless that TPE is classified as plastic and must satisfy the plastic requirements, the migration test of TPE shall be the same as the procedure for rubber due to the similar usage of TPE and rubber products.

Unlike EU 10/2011, where the types of plastic are approved through the positive list of starting substances, the Chinese plastic regulation approved 103 types of plastic (the previous 107 types of approved plastic types were modified and converged). If a Food Contact Material manufacturer would like to get approval for a new type of plastic, application shall be submitted to NHFPC.

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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