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Chinese Regulation Requirements on Imported Food Contact Materials and Articles

original article from CIRS

With the significant growth of purchasing power in Chinese market, an increasing number of imported kitchen utensils and other food contact products have been put into Chinese market. However, a majority of manufacturers and companies with limited knowledge about Chinese relevant regulations and standards caused that a large number of unqualified products entering into China. According to the document The Quality of Imported Food Contact Materials and Products in 2014 released by General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ), the disqualification rate of Chinese imported food contact products in 2014 reached to 6%, which is the worst situation in recent three years.

On the one hand, for Chinese customers, imported food contact products without Chinese labels or with non-standard Chinese labels will lead to incorrect usage which is the key reason for most accidents. More to the point, prolonged exposure to some hazardous substances migrated from unqualified food contact materials may cause chronic risk to customer human health. On the other hand, for exporters and importers, technical modification for complying Chinese label is required by CIQ, which will generate additional cost. More seriously, products will be directly rejected or destructed because failed to qualify safety and hygienic standards. In order to avoid unnecessary trade losses, CIRS strongly advise enterprises to conduct the self-test to guarantee the food contact materials and products complying with the requirements of relevant National standards and regulations and design the compliant Chinese label as well. The compliance guidance for imported food contact materials and products compiled by CIRS food team is as follow:

Step 1:According to the materials, ingredients, features and production processing to confirm the product category, then further determine the product national standard which the food contact material or product should comply with.

Table 1 Thecorresponding product National standard for common imported food contact materials and products

Step 2: Check out if the food contact additives with certain dosage are allowed to be used in the food contact products or not, according to GB 9685-2008 and Notices published by National Health and Family Planning Commission (NHFPC). After the ingredients analysis, based on the laboratory testing, confirm the quality of the products are compliant with product National standard.

Table 2Highlights on the quality of imported food contact materials and products confirmation

Step 3: Apart from above imported food contact product safety and quality issues, enterprises shall take the Chinese label into account seriously. In accordance with Stipulation on Inspection and Supervision of Imported Food Contact Products and relevant product National standard, the content (exclude the trademark) in the label and specification shall be standard Chinese. Meanwhile, below information should be also indicated accordingly:

With the promulgation of new Food Safety Law in China, the concerns of legislation and supervision for food related products have reached a new height. In the last few years, NHFPC has been working on the revising of food relevant National standards. There have been 13 food contact materials and products related National standard drafts (including 2 basic National standards, 2 product National standards and 9 testing National standards) releasedby far. In addition, 11 new National standards are expected to be published in 2015. Food contact materials and products manufacturers, exporters and importers shall pay more attention to the updated Chinese regulations. In the meantime, CIRS will continually report the amendment and work on the analysis of the new regulations.

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