Announcement No. 6 of 2025, which released two amendment sheets and thirty-two new national food safety standards, was jointly issued by the State Administration for Market Regulation and the National Health Commission on September 25, 2025.
Four of these standards pertain to materials that come into touch with food, and they are as follows:
· Paints and Coatings for Materials and Articles in Contact with Food (GB 4806.10-2025).
· GB 4806.16-2025: Food Contact Silicone Rubber Products and Items.
· GB 31604.21-2025 Determination of Benzoic Acid, Phthalic Acid, and Benzene tricarboxylic Acid Migration in Materials and Articles in Contact with Food.
· GB 31604.64-2025 Determination of Citrate and Subacute Compound Migration in Materials and Articles in Contact with Food.
With a one-year transition period, the two product standards will be implemented on September 2, 2026. On March 2, 2026, the other two testing technique standards will go into effect.
Paints and Coatings for Materials and Articles in Contact with Food - GB 4806.10-2025. The following are the main updates:
| 1. Scope |
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The old standard's statement that "This standard does not apply to paper coatings" was eliminated. |
| 2. Definitions & Terms | Listed "Coatings that indirectly contact food but whose components may migrate into food, and the coatings (films) formed thereby" in the description. | |
| 3.Fundamental Needs | 3.2 Manufacturing Enterprises and 3.3 Using Enterprises now have additional requirements | |
| 4. Technical specifications | 4.1 Requirements for Raw Materials | "List of Resins" was replaced with "Basic Raw Materials": |
| "List of Resins" was replaced with "Basic Raw Materials": increased the number of substances from 105 in the 2016 edition to 346 in the 2025 version by adding a substantial number of fundamental raw materials to Appendix A. Revised usage restrictions for certain drugs. Significantly, the BPA specific migration limit was lowered from 0.6 mg/kg to 0.05 mg/kg. Additional specifications for BADGE and other epoxy derivatives. |
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| 4.2 Requirements for the senses | Emphasized the need for coatings to adhere to sensory standards when they are meant for direct food contact. For sensory needs, the phrasing was harmonized and unifieRequirements for the senses | |
| 4.3 Indicators of Physiochemistry | It was made clear that only coatings that come into direct contact with food are subject to the standards for overall migration, potassium permanganate consumption, and heavy metals (as Pb). In the notes for Overall Migration, the phrase "products specifically intended for infants and young children" was unified. changed "cooking utensils and tableware" to "cooking utensils" as the scope of the high-temperature test conditions for potassium permanganate consumption and heavy metals (as Pb). added a new prerequisite for Primary Aromatic Amines' (PAAs') total migration |
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| 5. Other | 5.1 Testing for Migration | Added a special clause: Inert substrates (like glass) may be used for testing if surface coatings of metal cans (body, end, pull-tab, etc.) exhibit changes (like coating detachment, blistering, and metal corrosion) when exposed to acidic food simulants under test conditions that would not |
| happen under normal use. 10% ethanol can be used in place of 4% acetic acid when employing an inert substrate is not practical. | ||
| 5.2 Labelling | The prior standard's explicit requirements were removed. Now consistently controlled by GB 4806.1, the requirement that "coating materials and articles to also be labelled with the material names of the substrate and the coating respectively" has been eliminated. |
GB 4806.16-2025: Food Contact Silicone Rubber Products and Articles. The following are the main updates:
| 1. Scope | Made it clear that only silicone rubber products and materials are covered by the standard. | |
| 2. Definitions & Terms | "Food contact silicone rubber materials and articles" was defined. | |
| 4.Fundamental Needs | 4.1 Requirements for Raw Materials |
A) The list of basic silicone rubber polymers from Appendix A.2 of the previous standard GB 4806.11-2016 was kept, but silicon dioxide and 1-ethynylcyclohexanol were authorized, and the use of basic raw materials "as needed in accordance with good manufacturing practice" was mandated.
B) Required silicone rubber additives to adhere to GB 9685 and pertinent government announcements. Note: Silicone rubber can still contain additives that were listed in the 2008 version of GB 9685 for use in rubber. |
| 4.2 Requirements for the senses | For sensory needs, the phrasing was harmonized and unified. | |
| 4.3 Indicators of Physiochemistry |
a) Resolved the previous ambiguity where rubber and silicone rubber were classified under GB 4806.11 by establishing that the new standard GB 4806.16-2025 for silicone rubber supersedes GB 4806.11-2016.
b) To conform to the standard specifications for plastics, |
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coatings, inks, and adhesives, the test conditions for potassium permanganate consumption and heavy metals (as Pb) were modified from 60°C, 0.5 hours to 60°C, 2 hours.
c) In accordance with German standards for silicone rubber, a new criterion for volatile matter was added, with a control limit of 0.5%. The precise test procedure is provided in the standard's Appendix B. The standard process is to dry at 100°C for one hour, then bake at 200°C for four hours. Note: It is necessary to have duplicate samples.
d) Maintained the ability to choose general migration test settings for articles with a contact time of no more than 24 hours and an estimated contact temperature of no more than 40°C. eliminated the requirement that 50% ethanol be used for fatty food simulants; instead, GB 31604.1 now universally governs the choice between vegetable oil and oil alternatives. |
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| 4.4 Additional prerequisites | Auxiliary materials including coatings, inks, and adhesives now have additional criteria to ensure compliance with other product standards. | |
| 5. Others | 5.1 Testing for Migration | Removed the unique clauses for choosing fatty food simulants from the previous standard and aligned the food simulant selection with GB 31604.1. |
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The recently published national standards include more thorough and specific regulations for product manufacture, along with several other important revisions and adjustments.
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Relevant businesses should quickly become acquainted with the revised standards, proactively evaluate the compliance of their products, improve quality control, and guarantee complete compliance with the new rules.
