强制性新国标今日实施：食品接触涂层迎来新门槛

The list of permitted base raw materials has expanded to 346, while testing and supply-chain accountability have tightened. Compliance must still be assessed against the specific raw materials, coating process, finished packaging and conditions of use.

Three anchors for the effective date

2026.09.02　Effective date

105 → 346　Number of base raw materials

0.6 → 0.05 mg/kg　Migration limit for bisphenol A where the relevant raw material is used

LEVEL 1 · SCOPE

What the Standard Covers

On 2 September 2026, GB 4806.10—2025, National Food Safety Standard—Coatings and Coating Layers for Food-Contact Materials and Articles, took effect, replacing the 2016 edition. National food safety standards are mandatory under Chinese law.

It covers paints and coatings used in food-contact materials and articles, including those in direct contact with food and those not in direct contact whose constituents may nevertheless migrate into food.

The 2016 edition expressly excluded paper coatings and coating layers; the 2025 edition removes that exclusion. Coatings on paper cups, bowls, food containers and food-packaging paper therefore now have a clearer regulatory reference.

For coated paper packaging, the paper and paperboard substrate must still comply with GB 4806.8—2022, while the paint or coating must comply with GB 4806.10—2025. Any plastic layer, adhesive or printing ink in the construction remains subject to the relevant requirements. A finished SKU must be assessed against a set of standards, not a single material report.

Research sources:National Health Commission Announcement No. 6 of 2025; National Food Safety Standards Database

LEVEL 2 · WHAT HAS CHANGED

Key Changes

Expanded raw-material list:According to the official interpretation issued by the Beijing Municipal Administration for Market Regulation, the number of permitted base raw materials has increased from 105 to 346. The new standard also consolidates base raw materials for paints and coatings previously covered by 23 related announcements.

Expansion does not mean that all 346 raw materials may be used without conditions. Companies must still verify each material’s identity, maximum use level, migration or residual limits, applicable food types and temperatures, coating thickness, and any restrictions for special populations.

Tighter bisphenol A limit:Where the relevant raw material is used, the migration limit has been reduced from 0.6 mg/kg to 0.05 mg/kg. This should not be misread as requiring the same fixed test for every coating, nor as a blanket ban on an entire class of materials.

Stronger finished-product testing:Coatings containing aromatic isocyanates, azo colorants or other substances that may generate primary aromatic amines must be tested on the cured, finished food-contact material or article. As a general rule, primary aromatic amines must not be detected, at a limit of detection of 0.01 mg/kg; where a specific migration limit already applies, the corresponding requirement governs.

Shared responsibility across the supply chain:Clause 3.2 requires coating manufacturers to control risks through formulation design, raw-material selection, production controls and information transfer. Clause 3.3 requires users to address seams and edges, effective barrier layers, curing conditions, coating use levels and information transfer.

This standard addresses food-contact safety. It does not establish a uniform VOC limit, nor does it mandate the wholesale phase-out of any particular material.

Research sources:Beijing Municipal Administration for Market Regulation interpretation of the new standard; official 2025 and 2016 texts

LEVEL 3 · CHAIN OF RESPONSIBILITY

Implications for Each Link in the Supply Chain

Coating, emulsion and additive suppliers:Each commercial grade must be traceable to the corresponding internal formulation version, with clear disclosure of raw-material restrictions, conditions of use and change-control responsibilities. Downstream users do not need trade secrets; they need enough documented information to complete a safety assessment.

Coated-paper mills:The base paper, coating grade, coat weight, drying and curing conditions, production line and food-contact surface must be incorporated into the product specification. Changes to the formulation, coat weight, temperature or line speed may alter the scope for which an existing report remains valid.

Packaging converters:Evidence must be tied to the finished SKU. A cup wall, rim, base, side seam, box corner and cut edge encounter different materials and processes; a drum of coating or a flat-sheet specimen cannot substitute for an assessment of the finished article.

Brand procurement and supply-chain teams:Specifications should first define the food type, temperature, contact time, hot-fill, refrigeration, reheating and number of use cycles. Reports must correspond to the actual supplier, grade, plant, construction and batch.

Testing, quality and regulatory teams:The test plan must specify sample construction, contact surface, food simulants, time, temperature, surface-area-to-volume ratio and curing state. The same standard designation does not mean that different SKUs can share the same conclusion.

LEVEL 4 · ACTIONS FOR THE EFFECTIVE DATE

What Companies Should Do Now

01 | Verify raw materials.Coating suppliers should check where each base raw material and additive appears in the positive lists, together with maximum use levels, specific migration limits, overall migration limits and residual limits, and build a version-controlled raw-material restrictions matrix.

02 | Map the construction.Coated-paper mills and packaging converters should map “substrate—coating—process—finished SKU—intended use,” identifying food-contact surfaces, seams, edges and effective barrier layers.

03 | Define the test scope.Determine whether paper coatings, indirect-contact scenarios, bisphenol A, other risk parameters and testing of the cured finished article are triggered, and verify the food simulants, time and temperature.

04 | Update documentation.Update declarations of compliance, supplier documentation, the applicability of test reports, batch traceability and change notifications. The information required by GB 4806.1 cannot be replaced by a generic statement that the product “complies with the new national standard.”

05 | Manage the transition.Create an inventory of legacy stock, legacy reports, work in progress, customer-held stock and undelivered orders. Neither the standard itself nor Announcement No. 6 prescribes a one-size-fits-all approach for every company; businesses should not unilaterally declare that everything remains valid or that everything must be scrapped.

The new standard broadens raw-material options while raising the bar for information transfer through to the finished package.

What needs updating today is not a single report, but an evidence chain covering raw materials, processes, constructions, intended uses and batches.