China: New National Standard for Food Safety Adhesives for Food
Published 2 April 2024
Sarah Xuan
On March 12, 2024, China’s National Health Commission (NHC) formally released the National Standard for Food Safety Adhesives for Food Contact Materials and Products (GB 4806.15-2024). It is China’s first product standard for adhesives for food contact materials and products and will be officially implemented on February 8, 2025.
The main contents of the new standard GB 4806.15-2024 are as follows: 1. Classification of adhesivesDepending on whether they are in direct contact with food, adhesives are categorized into two types, i.e., adhesives for direct contact with food and adhesives for indirect contact with food. Both need to meet the basic requirements of Standard GB 4806.1, while enterprises need to pay attention to reducing the amount of use, reducing the amount of residue, and other ways to achieve the whole chain control of its risks. 2. Raw material requirements for adhesives1) Depending on the different direct and indirect exposure risks, different control modes are adopted for primary raw materials. The standard Appendix A and B give the permitted use of basic raw materials and the use of requirements.2)The base materials for adhesives for direct contact are more stringent and can only be used with Appendix A listed and notified substances. Appendix B and other substances that have been evaluated for safety can be used for indirect contact. Base materials for direct contact can be used for indirect contact.3)The additives used in the adhesive should meet the requirements of Standard GB 9685 and the announcement. 3. Main test items for adhesivesThe main test items for adhesives include sensory, total migration, potassium permanganate consumption, heavy metals, and total aromatic amine migration. Among them, sensory, total migration, potassium permanganate consumption, and heavy metal test items are only applicable to the adhesive layer for direct contact with food; the test of total migration of aromatic amines is only relevant to adhesives containing aromatic polyurethanes and other adhesives that may produce aromatic amines. The test shall be carried out after the curing reaction of the adhesive, and the end product is required to carry out the migration test of aromatic-borne amines. 4. Specific Migration, Maximum Residue LevelsTo determine the specific migration amount, maximum residue requirements, etc., enterprises need to combine with the composition of the formula and check out the Standard GB 4806.15 appendix and Standard GB 9685. 5. LabelingLabeling identification should comply with the provisions of Standard GB4806.1. Adhesive products should be labeled with the product category (adhesive for direct contact with food, adhesive for indirect contact with food).
Compared with GB 4806.15-2021 (Draft), GB 4806.15-2024 is basically unchanged in general, with some minor changes in two places and the addition of a clause, as follows: 1. Article 4.3 added the requirement that relevant enterprises through the ways of “curing process control, product information transfer” and other ways to minimize the use of adhesives and residues; 2. The original clause 5.3.2.1 was “Adhesives for food contact materials and products shall comply with the provisions of Appendix A, Appendix B of this Standard and the physical and chemical indexes on relevant notices such as Specific Migration Limit (SML), Specific Mobility Limit (SML(T)), and Maximum Residue Amount (QM) for base resins, monomers, and other starting materials”. GB 4806.15-2024 amends “base resins, monomers and other starting materials” in the original clause to “base materials”. 3. GB 4806.15-2024 added the new clause 6.2.2: “Adhesive products shall be labeled with the product category (adhesives for direct contact with food, adhesives for indirect contact with food)”.
The new Standard GB4806.15-2024 for adhesives for food contact materials and products issued by the National Health Commission further improves the control structure of the new national standard, tightens the control restrictions on materials for food contact, and, at the same time, puts forward higher requirements for enterprises.