October brought important news in the field of Food Contact Materials for China. On the 7th of October 2023 the China’s National Health Commission (NHC) has approved an expanded usage of 5 new materials.

The new rules come with some clarifications on amounts and materials which must comply.

Three of these materials are food contact materials:

• C.I. Pigment black 7; Carbon black: which now is to be cleared for use in polyetheretherketone at a maximum use level of 0.5%.
• Copolymer of acrylamide, 2-methacryloxyethyltrimethyl ammonium chloride, itaconic acid, and N,N’- methylenebis acrylamide (CAS No. 214495-32-6) is to be cleared for use in paper and paperboard at a maximum use level of 1.5% (on dry weight basis). The specific migration level (SML) is non-detectable (ND) for acrylamide, where the detection limit (DL) is 0.01 mg/kg.
•  2-acetoxy-1,2,3-propanetricarboxylicacid tributylester (CAS No. 77-90-7) is to be cleared for use in printing ink in indirect contact with food at a maximum use level of 10%. The SML is 60 mg/kg (calculated based on the sum of SMT (T) Group 32 substances).

The last two materials are new resins:

• Polymer from 1,4-terephthalic acid, sebacic acid and 1,2-ethylene glycol (CAS No. 25067-21-4) is to be cleared for use in coatings and coating layers at the necessary use level. The SMLs are 7.5 mg/kg (as 1,4-terephthalic acid) and 30 mg/kg (as 1,2-ethylene glycol). This substance may only be used for surface coating of PET films.
• 2-Propenoic acid, 2-methyl-,polymer with butyl 2-methyl-2-propenoate, ethyl 2-propenoate and methyl 2-methyl-2-propenoate, salts with 1,4-benzenediol-epichlorohydrin-4,4'- methylenebis [2,6-dimethylphenol]poly mer-2- (dimethyulamino) ethanol reaction products is to be cleared for use in coatings and coating layers at a maximum use level of 20% (as painting formula). The SMLs are 6 mg/kg (as 2-Propenoic acid); 0.6 mg/kg (Quinol); 18 mg/kg (N,N-dimethylethanolamine); 0.2 mg/kg [calculated based on the sum of the polymer of 4,4-methylenebis(2,6-dimethylphenol), 4,4-methylenebis(2,6-dimethyl91phenol), and epichlorohydrin (TMBPF- DGE), TMBPF-DGE∙H2O, and TMBPF-DGE∙2H2O]; and 0.05 mg/kg (calculated based on the sum of TMBPF-DGE∙HCl, TMBPF-DGE∙2HCl, and TMBPF-DGE∙HCl∙H2O).

For all of  above restricted use requirements must be labeled in accordance with the provisions of the standard GB 4806.1 (*).

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(*) GB 4806.1 = National Chinese Food Safety Standard -- General Safety Requirements on Food Contact Materials and Articles

Post 6/11/2023