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As the new Food Safety Law will come into effect in Oct, 2015, its corresponding standards are being completed actively. National Health and Family Planning Commission ( NHFPC) released 21 Food Contact Material (FCM) standards draft in August, 2015. The differences between the primary standard and newly draft standards are listed as follows:

Draft Standard Name	The differences between the primary standard and newly draft standards
General safety requirements for food contact materials and its articles.	This is the first famework regulation of FCM in China its highlights are listed behind this table
General principle of migration test for food contact materials and its articles ( GB 5009.156)	This standard will repalce GB/T 5009.156–2003 General principle for the determination of migration of packaging material and their products Compare with GB/T 5009.156–2003, this standard has following changes: ——amended this standard name as General principle of migration test for food contact materials and its articles ——amended the standard layout ——amended the term and defination ——added the general principle of testing ——amended the reagent and material ——amended the facility and appliance, and added the use requirement of testing tank ——amended the sampling and sample preparation method ——amended the area determination, added the requirement of food simulatent volume/contact area ratio ——amended sample cleaning procedure ——amended the testing method ——amended the result description
Food contact materials and its articles— D etermination of phthalate esters content and migration	This standard will replace GB/T 21928-2008 Determination of phthalate esters in food plastic packaging materials Compare with GB/T 21928-2008, this standard has following changes: ——amended the standard format according to the GB/T 1.1 Guide rule of standardization Part 1: result of standard and compile rule —— amended the name of standard ——amended the applicable scope of the standard ——amended the testing method ——amended the detectable limit
Food contact materials and its articles—Determination of 2,4,6-triamino-1,3,5-trazine (melamine) migration	This standard will replace GB/T 23296.15-2009 Food contact material polymer — Determination of 2,4,6-triamino-1,3,5-trazine(melamine)in food simulants — High performance liquid chromatography Compare with GB/T23296.15-2009, this standard has following changes ——added liquid chromatography tandem mass spectrometry method to determine the testing result
Food contact materials and its articles— D etermination of diaminomethylbezen of complex food packaging material GB 5009.119	This standard will replace GB/T 5009.119-2003 Determination of diaminomethylbezen of complex for food packaging material Compare with GB/T 5009.157-2003 this standard has following changes ——amended the pretreatment method and changed the derivatization reagent from trifluoroacetic anhydride to heptafluorobutyric anhydride ——adopted capillary column as the analysis chromatographic column instead of packed column ——improved the detectable limit from 0.002mg/L to 0.0005mg/L ——added gas chromatography tandem mass-spectrograph determination method as the second method
Food contact materials and its articles—Determination of 11-aminoundecanoic acid in food simulants	This standard will replace GB/T 23296.12-2009 Food contact material — polymer — Determination of 11-aminoundecanoic acid in food simulant — High performance liquid chromatography Compare with this standard GB/T 23296.12-2009 this standard has following changes ——amended the standard format according to the GB/T 1.1 Guide rule of standardization Part 1 ： result of standard and compile rule ——amended the name of the standard ——amended the sample preparation condition ——amended the food simulants category —— amended the calculation formula
Food contact materials and its articles—Determination of polychlorinated biphenyl in food packaging paper
Food contact materials and its articles — Determination of di(2-ethylhexyl) adipate migration	This standard will replace GB/T 20499-2006 Method for the determination of di(2-ethylhexyl) adipate migrating from polyvinyl chloride film in contact with foodstuffs and GB/T 20500-2006 Method for the determination of di(2-ethylhexyl)adipate and di-n-octyl adipate in polyvinyl chloride film Compare with GB/T 20499-2006, GB/T 20500-2006this standard have following changes: ——amended the standard name as Food contact material and its articles determination of di(2-ethylhexyl) adipate migration ——integrated different di(2-ethylhexyl) adipate content and migration determination method in this standard uniformly ——added several new food simulants for migration testing according to GB 5009.156-20××
Food contact materials and its articles — Determination of perfluorooctane sulfonates （ PFOS ） and perfluorooctane sulfonate （ PFOA ）	This standard will replace the GB/T 23243-2009 Determination of perfluorooctane sulfonates (PFOS) in food packing material — High performance liquid chromatography-tandem mass spectrometry Compare with GB/T 23243-2009this standard has following changes: ——amended the standard name as Food contact material and its articles determination of perfluorooctane sulfonates （ PFOS ） and perfluorooctane sulfonate （ PFOA ） ——amended the applicable scope ——amended the determination method
Food contact materials and its articles — Determination of methyl methacrylate migration
Food contact materials and its articles — Determination of styrene and ethylbenzene	This standard will replace the GB/T 5009.98-2003 Method for analysis of hygienic standard of unsaturated polyester resin and glass fibre reinforced plastic used as food container and packaging materials and GB/T 5009.59-2003 Method for analysis of hygienic standard of polystyrene resin for food packaging Compare with GB/T 5009.98-2003 and GB/T 5009.59-2003this standard has following changes — —amended the standard name as Food contact material and its articles — Determination of styrene and ethylbenzene ——adopted capillary column as the analysis chromatographic column instead of packed column ——added the extraction method for pretreatment of insoluble sample
Food contact materials and its articles — Determination of caprolactam content and migration	This standard will replace the GB/T 5009.125-2003 Determination of 6-caprolactam in nylon 6 resin and its articles and GB/T 23296.20-2009 Food contact material –determination of caprolactam and caprolactam salt in food simulants — Gas chromatography Compare with GB/T 5009.125-2003, GB/T 23296.20-2009 this standard has following changes: ——amended the standard name as Food contact material and its articles — Determination of caprolactam content and migration ——added new food simulant according to GB 5009.156-20×× ——adopted liquid chromatography instead of gas chromatography as the determination method of caprolactam ——added the pretreatment method for the determination of caprolactam in food contact material and its articles.
Food contact materials and its articles — Determination of kreosote in cork
Food contact materials and its articles-Determination of epichlorohydrin content and migration	This standard will replace GB/T 23296.7-2009 Food contact materials–Determination of epichlorohydrin in plastic–High performance liquid chromatography Compare with GB/T 23296.7-2009–2003 this standard has following changes ——amended the standard name as Food contact material and its products–Determination of epichlorohydrin content and migration ——added paper product as new determination applicable scope ——added determination method for epichlorohydrin migration
Food contact materialsand its articles — Determination of maleic acid and maleic anhydride migration	T his standard will replace GB/T 23296.21-2009 Food contact material determination of maleic acid and maleic anhydride in food simulants–High performance liquid chromatography Compare with GB/T23296.21-2009this standard has following changes: ——amended the name of the standard ——amende the high performance liquid chromatographic condition ——amended the detectable limit
Food contact materials and its articles— D etermination of acrylamide migration	\This standard will replace B/T 23296.9-2009 Food contact material- polymer-determination of acrylamide in food simulants –High performance liquid chromatography Compare with GB/T 23296.9-2009this standard has following changes: ——amended the standard name as Food contact material and its products—Determination of acrylamide migration ——amended the applicable scope ——the food simulants shall be prepare according to GB5009.156 General principle of migration test for food contact materials and articles. ——amended the treatment process of oil base food simulants ——amended the liquid chromatographic condition ——amended the calculation formula
Food contact materials and its articles — D etermination of vinyl chloride content and migration	This standard will replace GB/T 5009.122-2003 Determination of residual ethylidene dichloride in polyvinyl chloride resin and product for food container and packing material , GB/T 5009.67-2003 Method for analysis hygienic standard of products of polyvinyl chloride for food packaging , GB/T 5009.68-2003 Method for analysis of hygienic standard of perchorovinyl-coating for inner wall of food container GB/T 23296.14-2009 Food contact material–polymer-determination of vinyl chloride in food simulants–Gas chromatography , GB/T 23296.13-2009 Food contact materials–Determination of vinyl chloride monomer in plastic –Gas chromatography Compare with GB/T5009.122-2003, GB/T5009.67-2003, GB/T5009.68-2003, GB/T23296.14-2009, GB/T23296.13-2009, this standard has following changes: ——amended the standard name as Food contact material and its articles—Determination of vinyl chloride content and migration ——amended the applicable scope of the standard
Food contact materials and its articles — Determination of ethylene glycol and diglycol migration
Food contact materials and its articles — Method for analysis of hygienic standard of products of foamed polystyrene for food packaging	This standard will repalce GB/T 5009.100-2003 Method for analysis of hygienic standard of products of foamed polystyrene for food packaging Compare with GB/T 5009.100-2003 this standard has following changes： ——this standard is only applicable to determinedichlorodifluoromethane in food packaging foamed polystyrene ——adopted capillary column as the analysis chromatographic column instead of packed column ——left out the sampling procedure
Food contact materials and its articles — Determination of isocyanate	This standard will replace GB/T 23296.22-2009 Food contact material –determination of isocyanates in plastic–High performance liquid chromatography Compare with GB/T 23296.22-2009 this standard has following changes ： ——amended the standard name as Food contact material and its article determination of isocyanate ——added hexamethylenediisocyanate as analyte
Food contact materials and its articles — Method for analysis of hygienic standard of papers for food packaging	This standard will replace fluorescent material determination section of GB/T 5009.78-2003 M ethod for analysis of hygienic standard of papers for food packaging Compare with GB/T 5009.7-2003 this standard has following changes: ——added the preparation and pretreatment method ——added specific applicable scope of the standard

20 standards are related to the determination method for food contact material provide technical support to product testing, and restricted substance control for which stipulated in GB 9685. Relevant testing organization and stakeholder should attach more attention.

Among of these standards, General safety requirements for food contact materials and its products perhaps is the biggest concern in the industry. Its status is equal to the framework regulation EC 1935/2004 in EU food contact regulatory, which is applicable to all kinds of food contact material.

General safety requirements for food contact materials and its articles stipulated basic requirements of food contact material and its articles, limit requirement, compliance principle, testing method, traceability and label requirement of the product.

Highlights of General safety requirements for food contact materials and its articles (draft)

1. Non -Intentionally Added Substance (NIAS)

The description of NIAS appeared in Chinese food contact material regulation for the first time. In section 2 of the regulation, the NIAS is described as: the impurities, by-product in the manufacture process or decomposition product of production, management and using process in the food contact material and its products.

2. Functional Barrier

The section 3.6 of this regulation specified that for the substance which is not in direct contact with food, separated from food by an effective barrier layer, and not contained in existing national Food Safety Standards (GB 9685), its amount that migrating to food shall not be detectable (DL = 0.01 mg/kg). This is very important and meaningful, cause it will ease the burden for both industry and Chinese authorities as it will permit to use safe food packaging materials without the need for premarket review and approval. What needs to be stressed is that the carcinogenic, teratogenic, mutagenic substances and nanometer substances are not applicable for this section.

3. Declaration of Compliance (DoC)

Section 8.4 specifies that a DoC should includes information on applicable regulations and standards, restricted substances and their limits, risk assessments for NIAS, as well as the overall migration amount.

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The Construction Progress and Highlights of Food-Related Product Standard System in China