China Publishes Draft Amendment on Food-Contact Coatings and Coating Layers

On December 11, 2023, China’s National Health Commission (NHC) published a draft amendment of GB 4806.10 on food-contact coatings and coating layers (Draft Amendment), along with other draft standards for various food, food additives, other food-contact materials, and testing methods. 

The current version of the Coatings Standard (GB 4806.10-2016), published in 2016, only applies to coatings applied to the direct food-contact side of food-contact materials and articles and to the resulting coating layers. Further, the current Coatings Standard explicitly excludes paper coatings and coating layers from its scope. The Draft Amendment proposes a new definition that covers coatings and coating layers that may directly or indirectly contact food and which may result in components being transferred to food. The exclusion of paper coatings and coating layers is also removed.

The Draft Amendment contains a positive list of 358 base polymers and monomers, including more than 60 non-polymeric substances that may be used as monomers and other starting materials. (The current Coatings Standard only includes 105 permitted base polymers in its Appendix A.)

Also similar to the amended Plastics Standard, a new specification on the total migration of primary aromatic amines (PAAs) of “not detectable” at a limit of detection (LOD) of 0.01 mg/kg was added. This specification is applicable only to coatings and coating layers that contain aromatic isocyanates and azo dyes.

Comments on the Draft Amendment are due to NHC by February 10, 2024.