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Multiple new national standards for FCM food contact materials have been released!
Time：
2025-04-01
The National Health Commission has released a revised version of the GB 31604 series testing methods for five food contact materials and one additive standard GB 9685-2016.
On March 27, 2025, the National Health Commission announced 50 national food safety standards, including 5 GB 31604 series testing methods and 1 amendment to the additive standard GB 9685-2016 related to materials and products in contact with food.
The implementation date of the 5 GB 31604 series testing methods is September 16, 2025, with a buffer period of only six months.
The amendment to the additive standard GB 9685-2016 will be implemented from the date of approval, which is March 16, 2025, and requires relevant enterprises to implement it immediately.
GB 31604 series testing method update instructions
Among the 6 testing methods released this time, ortho benzene is an updated method, with a focus on adjusting the pre-treatment method for soaking with ≥ 50% ethanol. Added a testing method for the migration of ortho benzene in oil containing simulants.
The new version of GB 31604.31 explicitly adds the determination of the content and migration of 1,1-dichloroethylene and 1,1-dichloroethane.
A new testing method for the migration and release of nitrosamines has been developed, which addresses the issue of the lack of standard testing methods for nitrosamines in the new rubber version requirements of GB 4806.11-2023.
GB 9685 Amendment No.1 Update Explanation
GB 9685 Background
The standard system for food contact materials in China consists of four parts: basic standards, product standards, inspection methods, and production specifications. GB 9685 is a fundamental standard in China's standard system, which specifies the requirements for the use of additives in food contact materials and products.
GB 9685 "National Food Safety Standard for the Use of Additives in Food Contact Materials and Products" has undergone four revisions: the first edition was published in 1988, followed by three revisions in 1994, 2003, and 2008. GB 9685-2016 is the fourth revision of GB 9685 and the currently valid version. The revised version released this time is valid in parallel with GB 9685-2016 and will be officially implemented from the date of approval on March 16, 2025.
Revision content
1. Update of additive list for silicone rubber production
In this amendment, it is clarified that "additives allowed for rubber in GB 9685-2008 can also be used in the production of silicone rubber". The current list of additives allowed for the production of silicone rubber is:
·Additives listed in Table A.7 of GB 9685-2016
·GB 9685-2008 allows additives for rubber
·Announcement of the National Health Commission on Food Related Products (Applicable Material Type: Silicone Rubber)
2. How to use food additives listed in GB 2760 for food contact materials and products
According to A.13 of GB 9685-2016:
·a) Without considering the technical functions of the food product itself, the substances listed in Table A.2 of GB 2760 actually meet the relevant requirements of this standard;
Starting from February 8th, 2025, GB 2760-2024 "National Food Safety Standard for the Use of Food Additives" (referred to as the new standard) has officially replaced GB 2760-2014 (referred to as the old standard). In this update, the content of Table A.2 from the old standard has been merged into Table A.1 of the new standard. In this situation, it has caused certain difficulties for the use of food contact materials and products by related enterprises.
In this amendment, it is specified that the standard's era number is GB 2760-2014.
·b) Without considering the technical functions of the food product itself, the substances listed in Table A.2 of GB 2760-2014 actually meet the relevant requirements of this standard.
3. Update of Appendix A
Appendix A of GB 9685 specifies the permissible additives and usage requirements for food contact materials and products.
·Limited modifications
The substances in Tables A.1, A.2, A.5, and A.6 have been updated.
·Change of Material Name
4. Update of Appendix B
Appendix B in GB 9685 is the specific migration total limit, namely SML (T). Table B.1 lists the SML (T) group numbers, CAS numbers, restricted substance names, SML (T), and restriction instructions corresponding to the specific migration total limit in Appendix A. In GB 9685-2016, a total of 32 specific migration limits are provided.
Three sets of limited quantities have been added to this modification order.
·Appendix D
Appendix D defines the abbreviations for various plastic materials in Appendix A. The abbreviations for 31 types of plastics, such as AS, are listed in GB 9685-2016, ABS, PA, PET, PBT, etc.
The abbreviation and English name of polyvinyl alcohol have been added to this modification order.
The amendment order for the additive standard GB 9685-2016 has officially come into effect. This update has expanded the usage list of silicone rubber materials and products. For enterprises that encounter difficulties in new research and development or in the original product design process, they can consult the rubber list in GB 9685-2008 according to their own needs in order to better complete product design and research and development.
For enterprises involved in the material related materials mentioned in this update, such as plastic, paint, adhesive, and paper and cardboard production enterprises, they should conduct compliance reviews of their own products, evaluate existing products to ensure compliance with the requirements of the new regulations. If you have any questions about the compliance of food contact materials and additives used in products, please feel free to contact us.
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