Interpretation on Key Points of Food Contact Ink and Composite Materials National Standards (Draft)

On October 15^th, 2020, National Health Commission of People’s Republic of China (NHC) published the draft of 18 National Food Safety Standards including gum base and its ingredients for public comments. The deadline to submit comments is November 30th, 2020. There are 5 food-related product standards, which are ink, bamboo and wood materials and articles, composite materials and articles, paper and paperboard materials and articles, detergents.

Among them, the ink standard, bamboo and wood materials and articles standard are newly formulated standards, and the other three standards are the revisions to existing national standards. The main points of each standard are as follows:

A. Food contact ink

1. Definition

Food contact ink: It refers to the ink which is printed on food contact materials and articles that directly contact with food or indirectly contact with food, but its ingredients may be transferred to food. It also includes varnishes used with inks .

2. Classification and requirements

Classification	Requirements
Inks direct contacted with food	Basic raw materials	The basic raw materials should be approved to be used in GB 2760 and related announcements , the quality specifications should meet the requirements of relevant standards.
	Additives	The additives should be approved to be used in GB 2760 and related announcements , the quality specifications should meet the requirements of relevant standards.
Inks indirect contacted with food	Basic raw materials	The resin should be the resin approved to be used for food contact materials and articles. Colorants cannot use lead, mercury, cadmium, chromium (VI), arsenic, antimony, selenium or their compounds . The colorants should meet the colorant’s purity restrictions in GB 9685.
	Additives	The additives should meet the requirements of GB 9685 and related announcements .

Interpretation:

One point of the standard is to clarify the basic raw materials and additives used in inks direct and indirect contacted with food: The basic raw materials and additives of inks direct contacted with food should use the substances that can be directly added to food, the list of substances should comply with GB 2760 and related announcements. This has strict requirements on the formulation of inks for direct food contact. While the basic raw materials for inks indirect contacted with food should be the basic materials that have been passed the safety evaluation and allowed to be used in other materials, the list of additives should comply with GB 9685 and related announcements.

B. Food contact bamboo and wood materials and articles

1. Definition

Food contact bamboo and wood materials and articles: under the normal use condition, the materials or articles which made from bamboo, wood or cork that has already contact with food or food additives (hereinafter referred to as food), or have the possibility to come into contact with food or the ingredients may be transferred to food, including cork, vegetal fiberboard containers , etc.

2. Technical requirements

1) “No moth damages” in sensory requirements does not apply to cork materials and articles;

2) The “Overall migration” index in physicochemical indicators does not apply to food contact bamboo and wood materials and articles that do not use coatings, adhesives and inks. The physicochemical indicator of “Sulfur dioxide” is only applicable when water is used as the food simulant.

Interpretation:

This standard comprehensively considers the basic raw materials, auxiliary materials, adhesives, coatings and inks used in bamboo and wood articles. Therefore, in order to control the relevant risks from the source, the draft has added the principled requirements for the raw materials. At the same time, depending on the specific materials, the requirements for sensory items and migration indicators should also be classified and explained separately.

C. Food contact composite materials and articles

Compared with GB 9683-1988 Hygienic standard for composite laminated food packaging bag, the major changes are as follows:

1. Expand the scope of application

2. Increased the requirements for raw materials and additives

Specify and explain the materials of each layer, the basic resins, other basic raw materials and additives used in each layer.

3. Modified the sensory and physicochemical indicators

1) Sensory requirements are regulated by direct food contact layer .

2) Physicochemical indicator items are set according to the materials of each layer and final products of composite materials. And it is required that the composite materials using aromatic isocyanate and azo colorants should be tested for the migration of aromatic primary amines . For composite materials using inks and adhesives , the total solvent residual should be tested.

4. Label

The labeling shall be carried out in the order from the direct food contact layer to the outer layer.

Interpretation:

As the link between the specific product standard and the framework standard GB 4806.1-2016, this standard provides basic and principled regulations for the safety management of food contact composite materials and articles. Therefore, the basic requirements, raw material requirements, sensory requirements, physicochemical indicators of composite materials and articles have been reset from multiple directions like the materials of each layer, the final product of composite materials, and the direct contact surface.

D. Food contact paper and paperboard materials and articles

Compared with GB 4806.8-2016 National Food Safety Standard Food Contact Paper and Paperboard Materials and Articles, the major changes are as follows:

1. Modified the scope/ definition of the standard

2. Delete the Potassium Permanganate Consumption and Heavy Metal (as Pb) index in the physicochemical indicators.

3. Add the indexes of 1,3-Dichloro-2-propanol and 3-chloro-1,2-propanediol in physicochemical indicators.

Interpretation:

In this draft, the scope of application of standard has been reset and the description of the inapplicability of “Food contact regenerated cellulose materials and articles” has been deleted. The raw material requirements, sensory requirements, and physicochemical indicators in the standard were adjusted according to the actual use of products, industrial production process operations, and applicability of testing methods.

E. Detergent

Compared with GB 14930.1-2015 National Food Safety Standard Detergent, the major changes are as follows:

1. List the definition into the scope

This standard applies to detergents for food, tableware, drinking utensils, the tools and equipment that directly contact with food, food packaging materials and containers.

2. Refine raw material requirements

Appendix A was added to clarify the applicable raw materials in detergent products.

3. Increase the limit index of dioxan e

Interpretation:

Compared with 2015 version, the main changes in this revision are the refinement of raw material requirements and the addition of appendices. At the same time, considering the actual situation of food detergent formulations and the results of risk monitoring for dioxane content, the limit index of dioxane has been added and the product labeling requirements have been revised.

CIRS Group will also keep focus on the revision and release of the above standards.

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Reference

National Health Commission of People’s Republic of China (NHC) News

National Food Safety Standard Management Information System