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Two new national standards for food contact coatings and silicone rubber will be officially implemented on September 2, 2026

Time：

2026-07-02

The two new national standards for food contact coatings and silicone rubber, GB 4806.10-2025 "Coatings and Coatings for Food Contact Materials and Products" and GB 4806.16-2025 "Silicone Rubber Materials and Products for Food Contact", will be officially implemented on September 2, 2026.

Jiayu Testing has the capability to provide testing services for the two new standards mentioned above, and can issue authoritative testing reports with legal effect to safeguard the compliant production of food contact material enterprises. Welcome to contact us at 400-9269-886！

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GB 4806.10-2025

Coatings and Coated Materials for Food Contact Materials and Articles

The new national standard’s name has been adjusted from the 2016 version of "National Food Safety Standard - Coatings and Coatings for Food Contact" to the 2025 version of "National Food Safety Standard - Coatings and Coatings for Food Contact Materials and Products," strengthening the systematic supervision of "materials and products."

Extended scope of application

The new national standard removes the restriction of "not applicable to paper coatings and coatings" from the 2016 version, bringing paper coatings and coatings under the management scope of GB 4806.10. It is important to note that enterprises should pay attention to the actual classification of their products. Coatings applied to the surface of paper products to form a coating, used as paper coatings, fall under the management of GB 4806.10, while those added inside paper products, functioning as additives, are classified as paper additives and should be managed under GB 9685.

The new national standard covers coatings for metal cans, insulated cups, and other products in contact with acidic or high-temperature foods. It also newly includes coatings and their formed films that indirectly contact food but may transfer components into food, bringing them all under regulatory oversight.

Stricter control of harmful substances

The migration limit for bisphenol A has been significantly tightened: reduced from the original 0.6 mg/kg to 0.05 mg/kg, a decrease of over 90%, effectively lowering the risk of endocrine-disrupting substance migration.

A new total migration requirement for aromatic primary amines has been added: the total migration limit is set to "not detectable" (with a detection limit of 0.01 mg/kg), applicable to coatings containing aromatic isocyanates, azo colorants, and other substances that may generate aromatic primary amines.

A new limit for BADGE and its derivatives has been introduced: set at ≤0.01 mg/kg.

By simultaneously tightening limits and adding new controls, the migration risks of harmful substances from food contact materials have been significantly reduced, building a stronger defense for food safety.

Adjustment of detection requirements

Adjust the test conditions for potassium permanganate consumption and heavy metal migration (calculated as Pb): Change the scope of application for high-temperature conditions (boiling for 0.5h, then standing at room temperature for 24h) from "cooking and drinking utensils" to "cooking utensils." The 2025 edition will differentiate the test conditions for cooking utensils and drinking utensils, with the stringent high-temperature migration test applicable only to cooking utensils (e.g., woks, frying pans) to simulate material migration risks under actual cooking scenarios. Drinking utensils will no longer require testing under these stringent conditions, reducing unnecessary rigorous testing and better aligning with real-world usage scenarios.

Add special case handling for migration tests: For surface coatings on metal cans (including can bodies, lids, pull tabs, etc.) expected to come into contact with acidic food, if the test samples exhibit changes during total migration testing with 4% (volume fraction) acetic acid—such as coating peeling, bubbling, or metal corrosion—that would not occur in actual use, inert substrates may be used for sample preparation before testing. If this method is not feasible, 10% (volume fraction) ethanol may be substituted for 4% (volume fraction) acetic acid. However, this principle does not apply to testing for specific migration limits.

Expansion of the Safe Raw Material List

Significant expansion of basic raw materials: The new national standard will expand the list of permitted basic raw materials from 105 in the 2016 version to 346, providing the industry with a richer selection of compliant options.

Permitted use of high-molecular-weight polymers: It is explicitly stated that substances with a relative molecular weight greater than 1000Da, formed by polymerization or other methods from monomers, other starting substances, or basic polymers, are also permitted as basic raw materials for food-contact coatings and layers, provided they meet the corresponding restrictive requirements for basic raw materials.

Expanded use of salts of acids/alcohols/phenols: It is clearly stipulated that when the monomers or other starting substances used in polymer synthesis are acids, alcohols, or phenols, their sodium, potassium, and calcium salts (including acid salts and double salts) may also be used in the synthesis of the corresponding polymers, subject to meeting the applicable restrictive requirements.

New compliance requirements for additives: The raw material requirements now include provisions for additives, specifying that their use must comply with GB 9685 and relevant announcements.

GB 4806.16-2025

Silicone Rubber Materials and Products for Food Contact

Clarify the scope of application

GB 4806.16 is a standard specifically established by separating silicone rubber from the original rubber standards. It manages rubber and silicone rubber materials separately, where rubber falls under GB 4806.11-2023 and silicone rubber falls under GB 4806.16-2025.

Revision of physicochemical indicators

Revise the testing conditions for potassium permanganate consumption and heavy metals (calculated as Pb): extend from 60°C, 0.5h to 60°C, 2h, effectively tightening the requirements for these two indicators. It is recommended that companies conduct compliance testing and verification under the new standard's testing conditions to ensure products meet the updated requirements.

Add requirements for volatile organic matter (VOM): the limit is set at a mass fraction of ≤0.5% (or 0.5g/100g). Specific testing methods are detailed in Appendix B of the standard. This indicator strengthens the control requirements for residual volatile substances in silicone rubber. VOM is a test item where silicone rubber materials frequently fail to meet standards, and manufacturers should pay close attention to it.

Changes in test conditions

Compared to 50% ethanol (by volume), vegetable oil as a food simulant more accurately reflects the migration of substances from silicone rubber into fatty foods; when vegetable oil is not feasible, selecting chemical solvents for substitution tests according to GB 31604.1 also better represents actual migration levels. Enterprises should appropriately evaluate migration in olive oil and chemical alternative reagents to verify compliance with the new national standard requirements.

Two new national standards for food contact will be officially implemented on September 2, 2026, clarifying the scope of application, strengthening full chain supervision, raising safety limits, and imposing higher requirements on the entire industry chain. It is recommended that relevant enterprises conduct product evaluation and testing as soon as possible to ensure a smooth transition and guarantee product compliance and market access.

Jiayu Testing, as a professional third-party testing and certification service organization, has qualifications such as CMA, CNAS, CPSC, CCC, and has obtained laboratory accreditation from multiple authoritative certification institutions at home and abroad. It 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 coatings, silicone rubber, plastics, metals, glass ceramic enamel, bamboo, wood, paper and cardboard) 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！