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Definition of food contact materials and products:
Food contact materials and products are mainly for finished products. Under normal use conditions, various materials and products that have been or are expected to come into contact with food or food additives, or whose ingredients may be transferred to food, including packaging materials, containers, tools and equipment used in food during transportation, storage, sales and use, as well as inks, adhesives, lubricants, etc. that may come into direct or indirect contact with food. Excluding detergents, disinfectants and public water delivery facilities.
By destination country:
·China
·United States (USA)
·Germany
·France
·European Union (EU)
. Italy (Italy)
Introduction to destination country standards:
China Food Safety Law
my country’s current laws and regulations related to food contact materials are the Food Safety Law of the People’s Republic of China, which was officially promulgated and implemented in 2009. my country has promulgated and implemented more than 30 relevant health standards and method standards for food contact materials and products, covering plastics, food-grade coatings, metal products, ceramics, enamel, glass, paper and other materials. The main testing items include evaporation residue, potassium permanganate consumption, heavy metals (calculated as lead), decoloration test, dissolution test of heavy metals, residues of toxic and harmful monomers, microbial testing, etc. The regulatory requirements are detailed in the following table:
| serial number | material name | standard requirements |
| 1 | nipple | GB 4806.2-2015 |
| 2 | enamel products | GB 4806.3-2016 |
| 3 | glass article | GB 4806.5-2016 |
| 4 | Plastic resins for food contact | GB 4806.6-2016 |
| 5 | Plastic materials and products for food contact | GB 4806.7-2016 |
| 6 | Food contact paper and cardboard materials and products | GB 4806.8-2016 |
| 7 | Metal materials and products for food contact | GB 4806.9-2016 |
| 8 | Coatings and coatings for food contact | GB 4806.10-2016 |
| 9 | Rubber materials and products for food contact | GB 4806.11-2016 |
| 10 | Standard for the use of additives for food contact materials and products | GB 9685-2016 |
| 11 | Hygiene standard for composite food packaging bags | GB 9683 -1988 |
| 12 | Re-product safety national standard disinfected meal (drinking) utensils | GB 14934-2016 |
| 13 | Disposable chopsticks-Part 1.2: Wooden chopsticks | GB/T 19790.1.2-2005 |
| 15 | Inspection procedures for food contact materials Cork, wood and bamboo products | SN/T 2595-2010 |
| 16 | National Food Safety Standards Disinfecting Table (Drinking) Tableware | GB 14934-2016 |
U.S. food grade regulations:
The U.S. Food and Drug Administration (FDA) is part of the U.S. Department of Health, Education and Welfare and is responsible for the management of drugs, foods, biological products, cosmetics, veterinary drugs, medical devices and diagnostic supplies nationwide. In the United States, the FDA controls most products that come into contact with food mainly through the Food Additives Declaration Program (FAP). If a food additive or material that comes into contact with food is designated as usable through FAP procedures, the material is entered into the appropriate regulation in US FDA CFR 21 PARTS 170-189. Manufacturers should strictly follow food-grade regulations and produce qualified products and materials that come into contact with food. The main items tested include chloroform soluble extractables of different simulated liquids, extractables of different simulated liquids, density, melting point, harmful chemical substance monomers, extractable heavy metals, etc. See the following table for details of regulatory requirements:
| serial number | material name | standard requirements |
| 1 | Resin and polymer coatings | FDA 21 CFR175.300 |
| 2 | Components of paper and cardboard | FDA 21 CFR176.170 |
| 3 | Hard semi-hard acrylic and modified acrylic plastics (plexiglass) | FDA 21 CFR177.1010 |
| 4 | Food container lid with sealing gasket | FDA 21 CFR177.1210 |
| 5 | Copolymer of 1,4-cyclohexylidenedimethylene terephthalate and 1,4-cyclohexylidenedimethylene isophthalate | FDA 21 CFR177.1240 |
| 6 | Eva plastic | FDA 21 CFR177.1350 |
| 7 | melamine resin | FDA 21 CFR177.1460 |
| 8 | nylon resin | FDA 21 CFR177.1500 |
| 9 | Polypropylene, polyethylene, olefin polymers | FDA 21 CFR177.1520 |
| 10 | perfluorocarbon resin | FDA 21 CFR177.1550 |
| 11 | the polycarbonate | FDA 21 CFR177.1580 |
| 12 | vinyl phthalate polymer | FDA 21 CFR177.1630 |
| 13 | polystyrene | FDA 21 CFR177.1640 |
| 14 | styrene block polymer | FDA 21 CFR177.1810 |
| 15 | urea-formaldehyde resin | FDA 21 CFR177.1900 |
| 16 | phenolic resin | FDA 21 CFR177.2410 |
| 17 | Cross-linked polyester resin | FDA 21 CFR177.2420 |
| 18 | polyether sulfone resin | FDA 21 CFR177.2440 |
| 19 | polyoxymethylene copolymer | FDA 21 CFR177.2470 |
| 20 | polyoxymethylene homopolymer | FDA 21 CFR177.2480 |
| 21 | rubber | FDA 21 CFR177.2600 |
| 22 | ABS copolymer | FDA 21 CFR 181.32 |
| 23 | wood products | FDA 21 CFR178.3800 |
| 24 | Ceramics, glass, enamel utensils | FDA CPG 545.400 & CPG 545.450 |
| 25 | stainless steel products | GRAS |
| 26 | Copper products or copper-plated metal products or metal products | FDA CPG 545.500 |
| 27 | Butylene terephthalate | FDA 21 CFR177.1660 |
| 28 | chloride polymer | FDA 21 CFR177.1975 |
| 29 | poly (aryl ether ketone) resin | FDA 21 CFR177.1975 |
| 30 | polysulfone resin | FDA 21 CFR177.1655 |
| 31 | styrene-methyl methacrylate Copolymer | FDA 21 CFR177.1830 |
| 32 | polyphenylene sulfide resin | FDA 21 CFR177.2490 |
German LFGB
In September 2005, Germany’s new food and diet goods law LFGB replaced the food and daily goods LMBG. It is also known as the “Law on the Management of Food, Tobacco Products, Cosmetics and Other Daily Goods”. It is the most important basic legal document in Germany’s food hygiene management and the guideline and core for the formulation of other special food hygiene laws and regulations. In general, the test items in Articles 30 and 31 of the LFGB German Food and Daily Commodities Law include: sensory assessment of odor and taste transfer, overall migration in different food simulants, specific migration of specific substances in different food simulants, testing of components and extractable heavy metals, testing of transferable or volatile organic compounds, and testing of chemical hazardous substances according to the German Chemical Law. See the following table for details of regulatory requirements:
| serial number | material name | standard requirements |
| 1 | Shaped products/complete machine | LFGB 30&31 |
| 2 | polyethylene PE | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR Recommendation III |
| 3 | Polypropylene PP | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR Recommendation VII |
| 4 | polycarbonate PC | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 |
| 5 | polystyrene PS | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR Recommendation V&VI |
| 6 | Acrylonitrile polymer ABS/SAN | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245& BfR Recommendation VI |
| 7 | Polyamide/Nylon PA | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR Recommendation X |
| 8 | polyethylene terephthalate PET | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR Recommendation XVII |
| 9 | Silicone | BfR Recommendation XV |
| 10 | Ceramics/enamel/glass | DIN 51032 |
| 11 | Various stainless steel/iron products/metals/alloys/electroplated products | LFGB 35B 80.03-1/2 |
| 13 | non-stick coating | BfR Recommendation LI |
| 14 | organic coating | Reference to AP2004-1 |
| 15 | rubber | BfR Recommendation XXI |
| 16 | ethylene vinyl acetate copolymer | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR Recommendation XXXV |
| 17 | polyethylene vinyl acetate | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR III |
| 18 | acrylic acid/methylpropionate | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR XXII |
| 19 | polyoxymethylene resin | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR XXXIII |
| 20 | Polyurethane/Thermoplastic Polyurethane | EU Regulation (EU) No 10/2011 and its amendment EU 2020/1245 & BfR XXXIX |
France DGCCRF
French DGCCRF is the English abbreviation for French food safety regulations. In addition to complying with the requirements of EU Regulation (EC) No 1935/2004, such products sold to France must also comply with local French regulatory requirements, including French DGCCRF 2004-64 and French Décret no 92-631. French regulations not only have special requirements for plastic and rubber products that come into contact with food, but also have special classification and requirements for metal products. For example, cookware with organic coatings, in addition to the coating surface that needs to be tested, also have corresponding requirements for the metal used as the substrate. Its test items include: comprehensive migration in different food simulation solutions, specific migration of a specific substance in different food simulation solutions, testing of transferable or volatizable organic compounds, peroxide value, testing of precipitated heavy metals, etc. See the following table for details of regulatory requirements:
| serial number | material name | standard requirements |
| 1 | various plastic | DGCCRF 2004-64 |
| 2 | rubber | DGCCRF 2004-64 |
| 3 | silica gel | DGCCRF 2004-64 |
| 4 | Ceramics, glass, crystal | DGCCRF 2004-64 |
| 5 | enamel | DGCCRF 2004-64 |
| 6 | pure stainless steel | DGCCRF 2004-64 |
| 7 | Uncoated steel (black steel plate)(for packaging) | DGCCRF 2004-64 |
| 8 | Metallic plated steel (tinplate)(for packaging) | DGCCRF 2004-64 |
| 9 | Organic coated steel (for packaging) | DGCCRF 2004-64 |
| 10 | Steel (non-packaging) | DGCCRF 2004-64 |
| 11 | Metallic plated steel and stainless steel (non-packaging) | DGCCRF 2004-64 |
| 13 | Organic coated steel and stainless steel (non-packaging) | DGCCRF 2004-64 |
| 14 | Coated aluminum and aluminum alloys | DGCCRF 2004-64 |
| 15 | Uncoated aluminum and aluminum alloys | DGCCRF 2004-64 |
| 16 | pure cast iron | DGCCRF 2004-64 |
| 17 | plated cast iron | DGCCRF 2004-64 |
| 18 | Organic coated cast iron | DGCCRF 2004-64 |
| 19 | tin and tin alloys | DGCCRF 2004-64 |
| 20 | zinc | DGCCRF 2004-64 |
| 211 | White plated metals and alloys | DGCCRF 2004-64 |
EU EU
The current EU regulation on food contact materials is Regulation (EC) No. 1935/2004 of the European Parliament and of the Council of 13 November 2004 on food contact materials.(Regulation No. 1935/2004/EC of The European Parliament And Of The Council Of 27 October 2004), which not only replaces the previously implemented Directives 80/590/EEC and 89/109/EEC, Moreover, it inherits and develops the previous laws and regulations in content. It is the latest EU basic framework regulation on food contact materials and articles, which puts forward strict limits on the total amount of migratory substances in food contact materials. The main test items include the overall migration in different food simulants and the specific migration of a specific substance in different food simulants: such as formaldehyde, primary aromatic amines, heavy metal elements, etc. See the following table for details of regulatory requirements:
| serial number | material name | standard requirements |
| 1 | plastic | 2011/10/EU &(EU)No 321/2011 &(EU)No 1282/2011 &(EU)2020/1245 |
| 2 | Ceramics/enamel/glass | 84/500/EEC&2005/31/EC |
| 3 | silica gel | AP2004-5 |
| 4 | organic coating | AP2004-1 |
| 5 | rubber | AP2004-4 |
| 6 | Cork | AP2004-2 |
| 7 | Wood/bamboo | AP2004-2 |
| 8 | paper and board | AP2004-2 |
| 9 | Metals and alloys in contact with food | EDQM Technical Guide Resolution CM/Res(2013)9 |
ItalyItalian
The Ministerial Decision of 21 March 1973 (Italy) Italian Health Management Decree. In addition to complying with the requirements of EU Regulation (EC) No. 1935/2004, food contact products exported to Italy also need to comply with local Italian laws and regulations, including the requirements of the Italian Official Gazette GU 283 on April 1962 and the Ministerial Decision of 21 March 1973 and its revised versions. In addition to stipulating the principled requirements for the safety of food-contact materials that are basically consistent with the EU Framework Directive, the decree also specifies the scope of application, penalties for violations of the law, and the amount of penalties. It is important to note that Italy has strict requirements for stainless steel products. See the following table for details of regulatory requirements:
| serial number | material name | standard requirements |
| 1 | plastic | Decree of 21 Mar 1973 |
| 2 | Silicone, rubber | Decree of 21 Mar 1973 |
| 3 | stainless steel | Decree 6 August 2015, n. 195 |
| 4 | glass | Decree of 21 Mar 1973 |
| 5 | ceramic | DM 04.04.1985 and 01.02.2007 |
| 6 | aluminum/aluminum alloy | Decree No. 76 of 18 April 2007 |
| 7 | metals and metal alloys | CM/RES(2013) 9 & GUIDELINES ON METALS AND ALLOYS |
| 8 | non-stick coating | Decree of 21 Mar 1973 |