With the significant growth of purchasing power in Chinese market, an increasing number of imported kitchen utensils and other food contact products have been put into Chinese market. However, a majority of manufacturers and companies with limited knowledge about Chinese relevant regulations and standards caused that a large number of unqualified products entering into China. According to the document The Quality of Imported Food Contact Materials and Products in 2014 released by General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ), the disqualification rate of Chinese imported food contact products in 2014 reached to 6%, which is the worst situation in recent three years.
On the one hand, for Chinese customers, imported food contact products without Chinese labels or with non-standard Chinese labels will lead to incorrect usage which is the key reason for most accidents. More to the point, prolonged exposure to some hazardous substances migrated from unqualified food contact materials may cause chronic risk to customer human health. On the other hand, for exporters and importers, technical modification for complying Chinese label is required by CIQ, which will generate additional cost. More seriously, products will be directly rejected or destructed because failed to qualify safety and hygienic standards . In order to avoid unnecessary trade losses, CIRS strongly advise enterprises to conduct the self-test to guarantee the food contact materials and products complying with the requirements of relevant National standards and regulations and design the compliant Chinese label as well. The compliance guidance for imported food contact materials and products compiled by CIRS food team is as follow:
Step 1:According to the materials, ingredients, features and production processing to confirm the product category, then further determine the product national standard which the food contact material or product should comply with.
On the one hand, for Chinese customers, imported food contact products without Chinese labels or with non-standard Chinese labels will lead to incorrect usage which is the key reason for most accidents. More to the point, prolonged exposure to some hazardous substances migrated from unqualified food contact materials may cause chronic risk to customer human health. On the other hand, for exporters and importers, technical modification for complying Chinese label is required by CIQ, which will generate additional cost. More seriously, products will be directly rejected or destructed because failed to qualify safety and hygienic standards . In order to avoid unnecessary trade losses, CIRS strongly advise enterprises to conduct the self-test to guarantee the food contact materials and products complying with the requirements of relevant National standards and regulations and design the compliant Chinese label as well. The compliance guidance for imported food contact materials and products compiled by CIRS food team is as follow:
Step 1:According to the materials, ingredients, features and production processing to confirm the product category, then further determine the product national standard which the food contact material or product should comply with.
Table 1 The corresponding product National standard for common imported food contact materials and products
| Product Category | The Corresponding Product National Standard |
| Plastic products |
GB 9687-1988 Hygienic standard for polyethylene product used as food container and tablewares GB 9688-1988 Hygienic standard for polypropylene product used as food container and tablewares GB 9689-1988 Hygienic standard for polystyrene product used as food container and tablewares |
| Rubber products |
GB 4806.2-1994 Hygienic standard for rubber nipple GB 4806.1-94Hygienic standard for foodstuff rubber products |
| Paper products |
GB 11680-1989 Hygienic standard of paper used for food packaging GB/T 24695-2009 Cellophane used for food packaging GB/T 24696-2009Parchment used for food packaging GBT 27589-2011Paper container set for food |
| Metal products |
GB9684-2011National food safety standard- stainless steel product GB 11333-89 Hygienic standard for aluminum-ware for food use |
| Ceramic products | GB 13121-1991 Hygienic standard of ceramics for food container |
| Enamelproducts | GB 4804-84 Hygienic standard for enamel as food container |
| Other products |
GB 4805-1994 Hygienic standard for epoxy phenolic resin coating for the internal lacquer of food cans GB 19790.1-2005 Disposable chopsticks-part 1:wooden chopsticks |
Step 2: Check out if the food contact additives with certain dosage are allowed to be used in the food contact products or not, according to GB 9685-2008 and Notices published by National Health and Family Planning Commission (NHFPC). After the ingredients analysis, based on the laboratory testing, confirm the quality of the products are compliant with product National standard.
Table 2Highlights on the quality of imported food contact materials and products confirmation
| Product Category | Food Contact Additive Review | Safety and Hygienic Items Testing | Notes |
| Plastic products | ▲ | ▲ | The ingredient shall be in the list of 107 Resins that can be used in food contact materialsor two newly approved resins. |
| Rubber products | ▲ | ▲ | Only natural rubber and silicone rubber are allowed to be used as raw materials of rubber nipple. |
| Paper products | ▲ | ▲ |
I. Recycle raw materials are forbidden to be used in paper container set. II. Paraffin or polyethylene which is used in paper based food contact products shall be food grade. |
| Coating | ▲ | ▲ | |
| Ink | ▲ | △ | |
| Adhesive | ▲ | △ | |
| Metal products | ▲ | ▲ | |
| Ceramic products | ▲ | ▲ | |
| Enamel products | ▲ | ▲ | |
| Glass products | ▲ | ▲ | |
| Other products | Case by case | ||
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PS. 1. “▲” means the mandatory National standard stipulate the products. “△”means that for the moment there are no National standard stipulating the products. 2. The application of food contact additives in metal, ceramic, enamel and glass are removed from Draft GB 9685. |
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Step 3: Apart from above imported food contact product safety and quality issues, enterprises shall take the Chinese label into account seriously. In accordance with Stipulation on Inspection and Supervision of Imported Food Contact Products and relevant product National standard, the content (exclude the trademark) in the label and specification shall be standard Chinese. Meanwhile, below information should be also indicated accordingly:
- Product name
- Product material
- Original country or region
- Oversea manufacturer name
- Name, address and contact of importer or agent
- If the product has the shelf lift, the best before date is necessary.
- If necessary, the applicable condition, warning mark and Chinese wary specification shall be indicated.
- Other mandatory contents based on specific product national standard.
With the promulgation of new Food Safety Law in China, the concerns of legislation and supervision for food related products have reached a new height. In the last few years, NHFPC has been working on the revising of food relevant National standards. There have been 13 food contact materials and products related National standard drafts (including 2 basic National standards, 2 product National standards and 9 testing National standards) releasedby far. In addition, 11 new National standards are expected to be published in 2015. Food contact materials and products manufacturers, exporters and importers shall pay more attention to the updated Chinese regulations. In the meantime, CIRS will continually report the amendment and work on the analysis of the new regulations.
Ms. Cathy Yu Team Leader of Food Safety and Regulatory Affairs Department, CIRS China
11F Dongguan Building, 288 Qiuyi Road, Binjiang District, Hangzhou, China, 310020
Tel : +86 571 8720 6538 | Fax : +86 571 8720 6533
Email: cathy.yu@cirs-group.com
