China Food Contact Material Testing Service

China Food Contact Material Testing

1. Chinese Standards for Food Contact Materials

Currently, China has established a comprehensive regulatory and standard framework for food contact materials and products, including general standards, product standards, testing standards, and production specification standards. Specific requirements for product information, such as compliance declarations and labeling, have also been introduced, forming a complete legal and regulatory system as follows:

(1) General Standards: GB 4806.1 "National Food Safety Standard—General Safety Requirements for Food Contact Materials and Products," GB 9685 "National Food Safety Standard—Standard for Use of Additives in Food Contact Materials and Products"

(2) Product Standards: Published standards include GB 4806.2~11, which cover food contact materials and products such as nipples, enamelware, ceramic products, glass products, plastic resins, plastic materials and products, paper and paperboard materials and products, metal materials and products, coatings and coatings, rubber materials and products, etc. Future standards will also be developed for bamboo and wood products, adhesives, composite materials, inks, lubricants, textile fibers, and other products.

(3) Testing Standards: GB 31604.1 "General Principles for Migration Testing of Food Contact Materials and Products," GB 5009.156 "National Food Safety Standard—General Principles for Pretreatment Methods of Migration Testing for Food Contact Materials and Products," GB 31604.2~49 standards for testing methods of food contact materials and products...

(4) Production Specifications: GB 31603 "National Food Safety Standard—General Hygiene Specifications for Production of Food Contact Materials and Products"

2. Verification of Labeling for Food Contact Products in China

Non-compliance of imported food contact products with Chinese laws, regulations, and standards is widespread. Trading parties often fail to pay sufficient attention to China's legal and regulatory requirements, especially regarding labeling issues, leading to frequent cases of imported food contact products being returned, destroyed, or required to undergo corrective measures by China's inspection and quarantine authorities due to non-compliant labeling. This results in significant economic losses for both trading parties.

According to the white paper "2015 National Quality Status of Imported Food Contact Products" released by the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ), in 2015, national inspection and quarantine agencies inspected a total of 108,007 batches of imported food contact products, valued at $671.672 million. These mainly included ceramic products, plastic products, metal products, paper products, household appliances, and products made of other materials, with glass products being the primary category among other materials. In 2015, 8,331 batches of imported food contact products were found non-compliant, with a non-compliance rate of 7.71%. Among these, 7,751 batches had non-compliant labeling. The main issues with labeling non-compliance were the absence of Chinese labels or discrepancies between the label content and regulatory requirements.

According to the "Regulations for the Inspection and Supervision of Imported Food Contact Products" issued by AQSIQ, the labels and instructions on imported food contact products or their sales packaging must use standardized Chinese characters (excluding trademarks) and meet the following requirements:
(1) The product name, material, country or region of origin, and the name, contact information, and address of the importer must be indicated;

(2) For products with a limited shelf life, the expiration date must be clearly marked in a prominent position;

(3) Products that may cause damage or pose risks to personal or property safety due to improper use must include usage conditions, warning symbols, or Chinese warning statements.

According to GB 4806.1-2016 "National Food Safety Standard—General Safety Requirements for Food Contact Materials and Products," products must provide sufficient information, including labels, instructions, and other identification content, as well as product compliance certificates, to ensure adequate information for safety assessments of food contact materials and products:

(1) Identification content must include the product name, material, compliance declaration with relevant regulations and standards, the name, address, and contact information of the producer and/or distributor, and the production date and expiration date (if applicable);

(2) The final products of food contact materials and products must also be labeled with "for food contact," "for food packaging," or similar wording, or bear a spoon and chopsticks symbol, unless the product has a clear food contact purpose;

(3) Products with special usage requirements must clearly indicate usage methods, precautions, intended uses, usage environment, usage temperature, etc. For products with usage conditions specified in relevant standards or those that may pose higher food safety risks if used beyond these conditions, the usage conditions must be indicated in a special or conspicuous manner.

3. How Can Production Enterprises Achieve Compliance?

(1) Compliance of Production Entities

According to Article 41 of the "Food Safety Law," high-risk food-related products such as packaging materials that directly contact food must obtain production licenses in accordance with national regulations on the management of industrial product production licenses.

(2) Compliance in Production Processes

Production must adhere to "GB 31603-2015 National Food Safety Standard—General Hygiene Specifications for Production of Food Contact Materials and Products."

(3) Product Compliance

According to Article 52 of the "Food Safety Law," producers of food-related products must test their products in accordance with food safety standards. Products can only be released or sold after passing the tests.

(4) Sales Compliance

Labeling must meet requirements, and compliance declarations must be provided as required.