Official FAQ: Common Questions Regarding China National Standards for Food Safety-Food Related Products

Recently, China CFSA has issued FAQs regarding National Standards for Food Safety. From our years of regulatory compliance experience, we’ve translated a selection of 7 frequently asked questions about food related products to help you better understand the current requirements in China.

Q1. When enterprises label the food contact materials and product information, how can they understand the stipulation of “shelf life (if applicable)”?

A1: The National Standard for Food Safety—General Safety Requirements for Food Contact Materials and Products (GB 4806.1-2016) stipulates the requirements for product information on food contact materials. Provision 8.3 stipulates that “the labeling content should include the product name, material, declaration of compliance with relevant regulations and standards, name, address and contact information of the producer and/or distributor, date of production and shelf-life (if applicable).” Among them, the shelf life only applies to products that need to be used within a certain period of time, enterprises should determine on their own according to the characteristics of food contact materials and products to determine whether the product needs to set a shelf life, and if so, it should be labeled in accordance with the standard requirements.

Q2. What national standards for food safety is applicable for food contact materials and products processed by natural materials such as rice dumpling leaves and stone pots?

A2: Food contact materials and products such as rice dumpling leaves and stone pots are traditional natural materials that have been used for a long time in China. At present, China has not yet established specific national food safety standards for food contact materials such as rice dumpling leaves and stone pots. The safety risk of such products should conform to the provisions of the National Standard for Food Safety—General Safety Requirements for Food Contact Materials and Products (GB 4806.1-2016), and enterprises should carry out their own safety assessment and management, so as to ensure that the level of substances migrating into food is not hazardous to human health when such materials come into contact with food under the recommended conditions of use.

Q3. How should additives be used in food contact materials such as bamboo materials that are not listed in the list of permitted additives in Appendix A of the “National Standard for Food Safety—Standard for the Use of Additives for Food Contact Materials and Product” (GB 9685-2016)?

A3: According to A.13 in Appendix A of GB 9685-2016, substances listed in Table A.2 of Appendix A of GB 2760-2014 are also allowed to be used as additives for food contact materials and products under the condition that they do not produce technical functions on the food itself. The use methods of the corresponding additives shall comply with the requirements of GB 9685-2016.

In addition, new varieties of additives proposed to be used in such food contact materials shall be submitted and declared through the administrative licensing procedure for new varieties of food-related products.

Q4. Is it available for materials and products not in direct contact with food to use substances that are not listed in the corresponding national food safety standards or relevant announcements?

A4: The National Standard for Food Safety General Safety—General Safety Requirements for Food Contact Materials and Products (GB 4806.1-2016) stipulates that food contact materials and products refer to all kinds of materials and products that have been or are expected to be likely to be in contact with food or food additives, or whose components may be transferred to food. Therefore, for materials and products that are not in direct contact with food, if their ingredients may be transferred to food, they fall within the scope of management of food safety standards, and their use of additives shall comply with the requirements of the National Standard for Food Safety Standard for the Use of Additives for Food-Contact Materials and Products (GB 9685-2016) or the relevant announcements, and the use of resins/basic raw materials shall comply with the requirements of the National Standard for Food Safety of the corresponding materials or relevant announcements.

However, according to GB 4806.1-2016, substances (non-carcinogenic, non-teratogenic and non-mutagenic substances or nano materials) not listed in the corresponding food safety national standards or relevant announcements can be used in the production of food contact materials and products on the outside of the effective barrier layer. Manufacturers of food contact materials and products shall carry out safety assessment and control of such substances so that the specific migration amount does not exceed 0.01 mg/kg, and ensure that the end product meets the requirements that the level of the substances migrating into food will not be hazardous to human health, will not result in a change in the nature of the food such as its composition, structure, or color or flavor, and will not have a technological function on the food when it comes into contact with the food under the recommended conditions of use.

Q5. How to select the type of chemical solvent and alternative test conditions for chemical solvent substitution test?

A5: The National Standard for Food Safety General Principles for Migration Tests of Food Contact Materials and Products (GB 31604.1-2023) stipulates that chemical solvents, such as 95% (v/v) ethanol, n-hexane, n-heptanol and iso-octane, can be used to replace the simulants of food containing oils and fats for oil and fat food products. The chemical solvent substitution test should adopt the most stringent test conditions, which are supported by scientific evidence and can most realistically reflect the migration status of actual oily food. The selection of specific chemical solvents and substitution test conditions can refer to relevant standards or guidelines for chemical solvent substitution test method, such as GB/T 23296.1-2009).

Q6. How should the food contact materials and products attached to prepackaged food be labeled?

A6: GB 4806.1-2016 stipulates the requirements for labeling content and location of food contact materials and products. For food contact materials and products sold together with food and used in conjunction with food, such as forks for instant noodles, straws for liquid milk, spoons in milk powder buckets, etc., such products are part of prepackaged food, and do not belong to the smallest sales package of food contact materials and products, so they do not need to be labeled on the packaging of prepackaged food.

Q7. What requirements should be met by multi-material composite for food contact materials and products?

A7: For composite or combined food contact materials, all types of materials should be in accordance with the provisions of the corresponding national food safety standards. Composite materials should also meet the requirements of the National Standard for Food Safety—Composite Food Contact Materials and Products (GB 4806.13-2023).

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Further Information

Food FAQ: Compilation of Common Questions Regarding China National Standards for Food Safety- General Questions

Official FAQ: Common Questions on China National Standards for Food Safety - Limits of Contaminants and Mycotoxins in Food

Official FAQ: Common Questions on China National Standards for Food Safety-Pathogenic Bacteria Limits

Official FAQ: Common Questions Regarding China National Standards for Food Safety-Food Product Standard