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Food Contact Materials Regulations Compliance Consulting
WESSLING is committed to providing the food industry with high-standard, one-stop solutions for testing and regulatory consulting.
China has seen a flurry of updates to its food contact material standards. Between 2024 and 2026, several new versions of the GB 4806 series—covering plastics, metals, and rubber—were successively implemented, bringing significant changes to migration limits and testing methods.
In response to the comprehensive overhaul of China’s regulatory framework for food contact materials, WESSLING offers businesses a one-stop service featuring high-standard testing in accordance with national standards and comprehensive regulatory consulting, helping you transition from a reactive approach to testing to a proactive approach to building a compliance system.
WESSLING's Regulatory Consulting and Compliance Support Services
WESSLING’s consulting services go beyond a simple interpretation of standard regulations; we serve as a compliance partner throughout the entire process—from product conception, R&D, and procurement to production and market launch. Our core consulting services include:
Formulation and Ingredient Compliance Screening and Positive List Review
By getting involved at the R&D or incoming materials stage, we verify whether the resins, additives, colorants, and other ingredients used in product formulations are included in the positive list specified in GB 9685 and related announcements, and assess their usage restrictions (such as Specific Migration Limits (SML) and Total Specific Migration Limits (SML(T))). This approach eliminates prohibited substances at the source and mitigates the risk of exceeding permissible limits.
Declaration of Conformity (DoC) and Establishment of a Technical Documentation System
In accordance with the general safety requirements of GB 4806.1, we assist companies in preparing and reviewing declarations of conformity, and in establishing a fully traceable technical dossier covering “product—raw materials—additives—supplier declarations.” We ensure that the content of the DoC is complete, logically consistent, and capable of withstanding scrutiny during market supervision spot checks.
Labeling and Marking Compliance Review
In accordance with the new labeling regulations, please review your product labels, compliance statements, and accompanying instructions to ensure that information regarding materials, conditions of use, microwave safety, maximum operating temperature, production dates, and responsible parties is complete, accurate, and conforms to standard terminology. This will help you avoid penalties resulting from improper labeling.
Design of Simulation Migration Test Strategies
Based on the anticipated most severe usage conditions for the product (food type, contact temperature and duration, and contact area-to-volume ratio), we design the most representative migration test protocols in accordance with the GB 31604.1 and GB 4806 series standards. This approach avoids waste caused by excessive testing while preventing compliance gaps resulting from overly lenient test conditions.
Supply Chain Compliance Management and Risk Classification
Conduct compliance audits, review test reports, and perform risk assessments on packaging and contact components supplied by multi-tier suppliers, and issue supplier compliance assessment reports. Assist companies in establishing supplier onboarding and dynamic monitoring mechanisms to intercept non-compliant materials at the supply chain level.
Non-compliance Remediation and Crisis Support
In the event of failed random inspections, excessive migration levels, or labeling complaints, our team of experts will promptly step in to identify the root cause, propose a phased corrective action plan and validation strategy, and provide technical documentation to support communications with regulatory authorities as needed, helping to resolve compliance issues.
Comparison of Cross-Border Trade Regulations and the “One Test, Two-Way Alignment” Approach
When a product is sold simultaneously in China and the EU, we conduct an in-depth comparison of China’s GB standards with EU regulations such as (EC) No 1935/2004 and (EU) No 10/2011 to identify the highest standard among the overlapping requirements. We then design a testing plan that provides compliance evidence for both domestic and international markets, significantly reducing testing costs.
China’s regulatory environment for food contact materials is evolving at an unprecedented pace. By partnering with WESSLING, you are ensuring that your product upgrades and brand reputation are backed by the most robust scientific expertise and precise guidance.
Introduction to China's National Standard System for Food Contact Materials
China’s national standards for food contact materials, with the GB 4806 series as their core framework, have established a comprehensive compliance chain that spans “from resin to finished product, and from positive lists to migration testing.” The core logic of this system is built on four pillars:
Pillar1. General Safety Requirements—GB 4806.1
As the “framework standard” for food contact materials, GB 4806.1 establishes general safety requirements for various materials and articles, including basic requirements, principles of conformity, testing methods, and product information and traceability.
Notably, in August 2025, the National Health Commission released a draft for public comment on the latest version of this standard. It clarifies safety assessment requirements for non-intentionally added substances (NIAS) and provides detailed compliance pathways for multi-material composites, composite materials, and coated products. In the future, this standard will replace both the current GB 4806.1-2016 and GB 4806.13-2023 standards. This revision signals a comprehensive upgrade to the general safety requirements.
Pillar 2. Material-Specific Standards—GB 4806 Series
The GB 4806 series covers virtually all materials: plastics (GB 4806.7), paper and paperboard (GB 4806.8), metals (GB 4806.9), coatings (GB 4806.10), rubber (GB 4806.11), bamboo and wood (GB 4806.12), inks (GB 4806.14), adhesives (GB 4806.15), and even the latest standalone standard for silicone rubber products introduced in 2025 (GB 4806.16). Each material has its own specific migration limits and compliance requirements.
Pillar 3. Positive List of Raw Materials—GB 9685
GB 9685, “Standards for the Use of Additives in Food Contact Materials and Articles,” employs a positive list system to clearly specify restrictions such as the permitted scope of use, maximum levels, and specific migration limits (SMLs) for additives, monomers, and polymerization aids in various materials.
Pillar 4. Standardized Testing Methods—GB 31604 Series
This series of nearly 70 standards serves as the core technical foundation for the closed-loop compliance system, covering everything from “General Requirements for Migration Testing” to precise methods for determining the migration levels and residue levels of hundreds of specific substances. The intensive updates to numerous method standards between 2025 and 2026 have further enhanced the scope and accuracy of testing.
Why choose WESSLING’s consulting services?
- Originating in Germany, with a focus on the local market: With over 40 years of experience in consumer goods and food analysis, we have a deep understanding of advanced EU standards. At the same time, we maintain close technical collaboration with Chinese food and drug regulatory authorities and the industry, ensuring that our consulting advice combines an international perspective with a thorough understanding of local realities.
- Seamless Integration of Consulting and Testing: Regulatory experts and laboratory analysis teams work in close collaboration to achieve an efficient closed-loop process encompassing “risk assessment—solution design—test validation.”
- Customized Solutions: We will tailor the scope and depth of our consulting services to your specific product materials (such as coated plant-based fiber products, silicone rubber, bamboo and wood, and inks) and supply chain characteristics, and map out the most cost-effective path to compliance.
- Continuous Empowerment, Growing with Standards: Choosing WESSLING is not just about selecting a project; it’s about gaining access to an external think tank that stays abreast of global developments in food contact material safety, helping you stay ahead of the curve in an ever-changing regulatory landscape.