The Draft Standard stipulates that it applies to food contact coatings and coating layers, and removes the exclusion of paper coatings and coating layers stipulated in the Current Standard. It expands the scope of application of the Current Standards. Paper coatings and coating layers are used for indirect food contact. The exclusion of the restriction on paper coatings and coating layers makes the Draft Standard applicable to coatings and coating layers with direct and indirect food contact. Correspondingly, the definition of food contact coatings and coating layers in the Current Standards are also changed from the coatings applied to food contact materials and products which directly in contact with food and the coating layers they form to those which are coated on food contact materials and products, come into direct or indirect contact with food, and their components may be transferred to food.
Both the Draft Standard and Current Standard involve technical requirements. Considering that additives and basic raw materials are both raw materials, the Draft Standard merges the requirements for raw materials and additives in the Current Standard into requirements for raw materials. The requirements for additives have not changed. They are still required to comply with GB 9685, which is China’s mandatory management standard for the use of additives in the production process of food contact materials and products, and relevant announcements. Regarding the requirements for raw materials, the Current Standard stipulates that the list of resins allowed to be used should comply with the provisions of Appendix A and relevant announcements, while the Draft Standard stipulates that the use of basic raw materials in food contact coatings and coating layers should comply with the provisions of Appendix A and relevant announcements.
Compared with Appendix A in the Current Standard, Appendix A in the Draft Standard increases the number of base polymers that can be used in food contact coating and coating layers from 105 to 358. To meet the actual needs of the industry, the supplemented base polymers include raw materials that have been evaluated for safety and have clear process necessity. The specific migration limit requirement for bisphenol A in the Current Standard is 0.6mg/kg. Concerning the relevant risk assessment results, the Draft Standard reduces the limit value to 0.05mg/kg, consistent with relevant revisions of other product standards. In addition, the Draft Standard deletes the migration limit of antimony elements in PET from the Current Standard.
Regarding migration experiments, the Draft Standard states that in cases where the surface coating of a metal pipe deforms, swells or rusts when exposed to acidic food simulants, an inert substrate such as glass may be used. When an inert substrate is not feasible, 10% ethanol can be used instead of 4% acetic acid. Regarding label identification, in addition to requiring label identification to meet general requirements, the Draft Standard also requires coating materials and products to identify the base material and coating material respectively according to relevant standards.
The Draft Standard is formulated with reference to relevant regulations and standards from other countries and regions, including the European Union, the United States, Germany, Switzerland and Japan. This is conducive to the unification of global industry standards in the field of food contact coating and coating layers.