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China Publishes New Draft GB Standards Related to Food-Contact Materials and Articles

China’s National Health Commission (NHC) published on October 15, 2020 five draft GB standards in relation to food-contact materials and articles, which are described below. 

Food-Contact Use Composite Materials and Articles: This is the second draft standard for composite materials and articles. Article 2.1 of the draft standard defines composite materials and articles as: “food-contact materials and articles of two or more layers, which are made from different or same materials by adhesion, hot melting or other ways.” Food-contact substances used in each layer, such as adhesives and printing inks, must comply with the corresponding GB standards. This draft standard also adds a provision to permit the use of uncleared substances separated from food by effective barrier(s), provided that their migration level does not exceed 0.01 mg/kg and that they are not carcinogenic, teratogenic, mutagenic, or in nano form. There are also some changes in the testing requirements for composite materials and articles. 

Food-Contact Use Printing Inks: This is a new draft standard. It classifies food-contact printing inks into two categories: (1) direct food-contact printing inks that are applied on the food-contact surface, which may only use base materials and additives permitted in GB 2760 and relevant announcements; and (2) indirect food-contact printing inks that are applied on the non-food-contact surface but may transfer to food, which may be produced from (a) base resins that are permitted for food-contact materials and articles, (b) colorants that comply with the purity requirements in GB 9685 (excluding those that are based on lead, mercury, cadmium, chromium (VI), arsenic, antimony, selenium and their compounds), and (c) additives cleared in GB 9685 and relevant announcements.

Food-Contact Use Paper and Paperboard: The draft Paper Standard will revise and replace the current GB standard on paper and paperboard (GB 4806.8-2016). The overall migration limit of 10 mg/dm2 remains unchanged, in addition to the specifications for lead, arsenic, fluorescent substances and formaldehyde. The draft standard does not include any language on the use of recycled fibers. A new provision in the draft standard requires that the use of printing inks and adhesives in paper and paperboard be in compliance with corresponding standards for food-contact use printing inks and adhesives. 

Food-Contact Use Bamboo and Wood Materials and Articles: This draft standard defines bamboo and wood materials and articles as those using bamboo, wood, or cork as raw materials, including cork stoppers and plant fiberboard containers. Compared with the previous draft standard on “bamboo, wood and cork materials and articles” published in 2016, the new draft standard makes revisions on various physicochemical specifications. For example, it removes the migration limits on three heavy metals (Pb, Cd, As) and adds a new migration limit on pentachlorophenol.

Detergents: This draft standard will revise and replace the existing GB standard on detergents (GB 14930.1-2015).  As in the current version, the draft standard categorizes detergents into two classes: Class A detergents used directly for washing food and Class B detergents used to wash food-contact utensils, tools, equipment, and food packaging materials and containers. The major changes include a new positive list of raw materials permitted for use in Class A detergents (Appendix A) and the addition of limitations on 1,4-dioxane (≤ 10 mg/kg for Class A and ≤ 30 mg/kg for Class B detergents). 

© 2020 Keller and Heckman LLPNational Law Review, Volume X, Number 296
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PackagingLaw.com is the premier online resource for the global packaging industry. It provides a wide range of information on laws and regulations—both in the U.S. and other countries throughout the world—that affect packages and packaging materials. PackagingLaw.com features news articles on current issues affecting the packaging industry, in-depth features, an Ask an Attorney section, links to packaging industry and government websites, and detailed information on the U.S. Food and Drug Administration (FDA) Food Contact Notification system.

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