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Revised interpretation of changes! GB 4806.1 "General Safety Requirements for Food Contact Materials and Products" is open for public consultation
Time：
2025-08-04
GB 4806.1 "National Food Safety Standard - General Safety Requirements for Food Contact Materials and Products" draft for comments released, learn about these main changes!
On August 1, 2025, the Secretariat of the National Food Safety Standards Review Committee publicly solicited opinions on 30 national food safety standards (draft for comments), including the "National Food Safety Standard for the Use of Food Nutritional Fortifiers". The deadline for collecting opinions is September 26, 2025. This solicitation of opinions involves two food related product standards, including GB 4806.1 "National Food Safety Standard - General Safety Requirements for Food Contact Materials and Products".
GB 4806.1 has released a draft standard and a draft for soliciting opinions in April and October 2023, respectively, and has solicited opinions twice. In order to revise the second version of the draft based on previous feedback and solicit opinions again, it is planned to replace both GB 4806.1-2016 "General Safety Requirements for Food Contact Materials and Products" and GB 4806.13-2023 "National Food Safety Standard for Composite Materials and Products in Food Contact" in the future.
Main changes in the draft for soliciting opinions on GB 4806.1
The draft for soliciting opinions has revised the scope of application, terminology and definitions, and basic requirements of the standard. At the same time, it has also revised and integrated the GB 4806.13-2023 revision limit requirements and compliance atoms, and revised product information. The standard structure has also changed from 8 chapters and Appendix A to 7 chapters and Appendix A, which is significantly different from the current 2016 version of the standard. The main changes are shown in the table below:
Original Chapter: 1 Scope
Main revision content: Delete the "limit requirement" (actually merged into the compliance principle), and add new terms and definitions.
Original Chapter: 2 Terms and Definitions
Main revision content: Revise the definitions of "food contact materials and products" and "effective barrier layer", and add a definition explanation for "2.15 final product".
Original Chapter: 3 Basic Requirements
Main revision content:
A、 3.3 Revise the term 'substance' in food contact materials and products to 'raw material';
B、 3.5 Add "Safety assessment and control requirements for unintentional additives";
C、 3.6 Revise relevant regulations to ensure the effectiveness of effective barrier layers;
D、 Add a new clause 3.7 to the existing clause 3.6, which states that the production of food contact materials and products shall comply with GB 31603.
Original Chapter: 4 Limited Requirements 5 Compliance Principles
Main revision content:
A、 Merge two clauses into a new clause "4 Compliance Principles", which is divided into two parts: "General Requirements" and "Requirements for Food Contact Materials and Products Composed of Multiple Materials";
B、 General requirements: Clearly allow the use of food raw materials that can also be used for the production of food contact materials (4.1.1.2), prioritize migration results (4.1.2.1), microbial limit requirements (4.1.3), restricted use requirements (4.1.4), and other clauses;
C、 Requirements for food contact materials and products composed of multiple materials: Refine the FCM requirements for materials and products, composite materials and products, coated products, etc., covering the current relevant requirements of GB 4806.13-2023.
Original Chapter: 6 Inspection Methods
Main revision content: changed to "5 Inspection Methods", with no change in content.
Original Chapter: 7 Traceability
Main revision content: changed to "6 Traceability", with no change in content.
Original Chapter: 8 Product Information
Main revision content:
A、 Change to "7 Product Information";
B、 The chapter structure is divided into three parts: "General Requirements", "Compliance Requirements", and "Label Identification";
C、 General requirements: The product information of food contact materials and products, as well as their raw materials, should include a declaration of conformity and label identification (7.1.1); It is stipulated that producers and operators should provide a declaration of conformity to downstream parties (7.1.2); The final product should have label identification (7.1.3);
D、 Declaration of conformity: Clarify the content elements and specific requirements that should be included in the declaration of conformity (7.2.1), and add special requirements and timeliness provisions for providing the Chinese name and CAS number (if applicable) of the raw materials used when necessary (7.2.1.3 and 7.2.2). Simultaneously integrate the existing product information requirements of GB4806.13-2023 (7.2.1.2);
E、 Label identification: Add the principle requirement of "complying with laws and regulations, national food safety standards, and relevant announcements" (7.3.1), clarify the content elements and specific requirements that should be labeled (7.3.2), and delete the exception in clause 8.5 of the original standard that products with clear food contact purposes may not be labeled with the food contact use or spoon chopstick logo.
Original Chapter: Appendix A: Diagram of Spoon Chopsticks Logo
Main revision content: No changes.
Compared with the current GB 4806.1-2016, this draft for soliciting opinions has strengthened the connection with GB 9685-2016 and related product standards in the revision, ensuring the coordination and unity of the food contact material standard system. The draft for soliciting opinions adds principles for the use of effective barrier layers, refines compliance requirements for various material products, and makes more specific provisions for label identification and compliance statements. The final revision should be based on the official release of the standard text in the future.
In the face of increasingly strict global control over food contact materials, Jiayu Testing has a professional testing technology team, equipped with advanced instruments and equipment, proficient in various regulatory standards, and specializes in providing FCM food contact material testing services for various food contact materials (such as plastics, coatings, metals, silicone, glass ceramic enamel, bamboo, paper, cardboard, etc.) in China, the United States, the European Union and its member states (France, Italy, Germany, etc.), Japan, South Korea and other countries to ensure that your products meet the regulatory requirements of various countries. Welcome to contact us at 400-9269-886!
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