Food packaging materials in China are regulated under the "Food Safety Law of the People's Republic of China", which applied on 1 June 2009. This law prohibits the import, use, or purchase of food-related products, including food packaging materials, that not complying with the applicable Chinese Food Safety Standards promulgated by the Chinese Ministry of Health (MOH).
Our Solutions to China FCMs Regulatory Compliance
As per the latest GB standards and NHFPC notifications, C&K Testing renders you one-stop solutions to China FCMs regulatory compliance, including
1. Identify whether the additives in your FCMs products are allowed substances;
2. Confirm the authorisation granted for the additives, including maximum usage, specific migration limits, maximum residue (QM) overall migration limits and other restrictions for use;
3. Food contact materials/articles and additives testing and compliance assessment;
4. Formulate Declaration of Conformity (DoC) on your behalf;
5. Help with notification of new types of food-related products;
6. Verify the identifications and labels of your FCMs products.
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New China FCMs Regulatory Framework
China National Health and Family Planning Commission (NHFPC) launched the work for the conformity of national standards as regards food safety in May 2014. The new China regulatory framework of FCMs gradually takes shape along with the publication of new standards. The newly released standards as regards FCMs can be divided into 3 categories, namely, general standards, product standards and testing standards.
Up to November 2016, NHFPC had issued two general standards GB 4806.1 for general safety requirements and GB 9685 for the use of additives, 11 product standards covering rubber nipples (effective on 22 September 2016), enamel articles, ceramic articles, glass articles, plastic resins, plastic articles, paper and paper board, metal materials, coatings, rubber materials and articles. Meanwhile, the requirements for bamboo, wood, adhesives, composite materials, inks, lubricants, textile fires are still under development. Notably, these product standards (excluding GB 4806.2 for rubber nipples) under the new China FCMs regulatory framework come into operation on 19 Apr. 2017.
The chart below is the new China FCMs regulatory framework:
China releases GB 9685-2016 and other food contact material standards
On 18 November 2016, National Health and Family Planning Commission of the People's Republic of China (NHFPC) has released 53 national standards as regards food safety including 2 general standards, 10 product standards (designed specifically for enamels, ceramics, glasses, plastic resins, plastics, paper and paper board, metal materials, coatings and rubber materials) and 40 testing standards. Meanwhile, the requirements for disinfection tableware and use of additives in food contact materials and articles are also updated. It shall be noticed that the two general standards “GB 4806.1-2016” and “GB 9685-2016” will come into force on 19 October 2017 and all other FCM standard will be implemented on 19 April 2017. More details
Guideline on DoC for Chinese food contact plastic materials released
Led by food contact materials (FCMs) panels of China National Food Industry Association, the Industry Guideline on Plastic Food Contact Materials regards as Responsibilities along the Supply Chain and Document of Compliance (DoC) (referred to as “Guideline”) was officially released on 19 April 2017. With a six-month consultation, it becomes the first industry guideline on Document of Compliance (DoC) in the field of food contact materials (FCMs). More details
FAQs on compliance with food contact materials regulations in China
Several food contact regulations in China have come into operation since 19 April 2017. The new China FCMs regulatory framework covers requirements throughout raw materials, manufacture management and testing. The wide coverage and great changes in relevant standards make it challenging for both Chinese operators and importers for China regulatory compliance. More details
Difficulties Faced in China FCMs Regulatory Compliance
1. The great number of additives in the new legislation makes the process to identify allowed substances and their restricted uses more complicated.
2. More stringent regulation for the use of additives.
3. The norm on Declaration of Conformity (DoC) is unclear.
Identifications of Food Contact Materials
Why recalls of food contact materials imported to China are so frequent?
It is common that imported food contact materials do not comply with Chinese laws and standards. However, greater care should be paid especially for their identifications and labels. Based on statistics, there is a considerable proportion of imported food contact products suffer from huge economic losses due to re-dispatch, destruction or correction by Chinese authorities caused by non-compliance of identifications and labels.
According to white papers of Quality Report of Imported Food Contact Products in China of Year 2015, Chinese Inspection and Quarantine Authorities (“Authorities”) had inspected 108,007 batches of imported food contact products worthy of USD 671.672 million, covering ceramic, plastic, metal and paper products, home appliances and other food contact materials and articles. Glass articles are primary products among the said food contact materials/articles.
In 2015, the Authorities found 8,331 batches of food contact products were non-compliant with relevant standards with a failure rate of 7.71%. Alarmingly, 7,751 batches of products failed to meet the relevant requirements due to their identifications as below:
1. Lack of Chinese identifications
2. The contents in the identifications do not comply with relevant stipulations.
What shall an identification or label include?
According to Norm on Inspection and Supervision of Imported Food Contact Products released by General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China (AQSIQ):
The labels and instructions on the imported food contact products or their packaging shall be prepared in regular Chinese characters (excluding trademarks) and meanwhile meet the following requirements:
(1) Product name, materials, country/region of manufacture, importer name, contact and address shall be indicated;
(2) Where the products are limited for use, use period shall be clearly indicated on a prominent place.
(3) Appropriate conditions, warning labels or Chinese warning instructions shall be available when any misuse can easily do damage to the products or endanger consumers’ health or their property safety.
In recent years, AQSIQ has released inspection and supervision measures in order toprotect consumers’ health and safety. Meanwhile, greater efforts are made in controlling the quality of imported products. Undoubtedly, the verification of food contact products identification is also a highlight.
By virtue of our local advantages and profound understanding of Chinese laws, regulations and standards as regards of food contact products, C&K Testing helps trading parties to learn about relevant requirements by tracking on quality notifications of imported products. We are devoted to rendering verification services for identifications of food contact products to avoid trade barriers.
C&K Testing can provide professional testing for food contact materials as per standards of different countries and regions. Besides, we can render you one-stop solutions integrating consulting, testing and certification. Please feel free to contact firstname.lastname@example.org if any question.