China’s New Standard for Food-Contact Adhesives: GB 4806.15-2024 Effective February 2025

The introduction of GB 4806.15-2024, China's National Food Safety Standard for Adhesives in Food Contact Materials and Products, marks a critical shift in the country’s food safety regulations. Set to become enforceable on February 8, 2025, this standard outlines comprehensive guidelines that manufacturers must follow when producing adhesives that come into direct or indirect contact with food. The goal is to ensure these materials do not pose any health risks, thereby enhancing the safety of food products within China and for exports.

Data sourced from SGS Digicomply Regulatory Compliance Software

Scope and Application

The GB 4806.15-2024 standard has a broad application, covering adhesives used in various food contact materials and products. These include packaging, containers, utensils, machinery, and other items that might directly or indirectly come into contact with food during production, processing, storage, or packaging. The standard categorizes adhesives into two main groups:

• Adhesives for Direct Food Contact: Used on surfaces expected to be in direct contact with food, such as adhesive layers in food packaging films.
• Adhesives for Indirect Food Contact: Applied on surfaces that do not directly touch food but are still part of the food contact material. These adhesives may still cause substances to migrate into food over time, hence their regulation is crucial.

This distinction between direct and indirect contact determines the level of scrutiny and specific requirements for each category.

Key Requirements for Adhesives

Basic Requirements

GB 4806.15-2024 sets stringent basic requirements for adhesives in food contact applications, aligning with China’s general food safety regulations, particularly GB 4806.1. Key stipulations include:

• Compliance with Safety Standards: Adhesives must meet safety criteria to ensure they do not release harmful substances that could contaminate food.
• Control of Safety Risks: Manufacturers must implement robust controls throughout the adhesive production process, including careful raw material selection and continuous monitoring.
• Minimization of Residual Adhesives: The amount of adhesive used, especially for direct contact, should be minimized to reduce potential harmful residues.

Raw Material Specifications

The standard provides detailed guidelines on the raw materials allowed for adhesives in food contact applications:

• Direct Contact Adhesives: Raw materials for these adhesives must meet stricter criteria, with specific substances and migration limits outlined in Appendix A of the standard.
• Indirect Contact Adhesives: While still regulated, materials for these adhesives have slightly less stringent requirements, as listed in Appendix B.

Technical Requirements

Sensory, Physical, and Chemical Indicators

GB 4806.15-2024 specifies sensory, physical, and chemical indicators that adhesives must meet:

• Sensory Indicators: Adhesives in direct contact with food should not alter the food’s sensory properties (odor, color, or taste).
• Physical and Chemical Indicators: The standard sets maximum allowable limits for various substances that can migrate from adhesives into food, such as a total migration limit of ≤ 10 mg/dm² and heavy metal limits.

Migration Tests and Limits

Migration testing is crucial to ensure that substances from adhesives remain within safe limits. The standard refers to GB 31604.1 for testing methods, which simulate real-world conditions.

• Specific Migration Limits (SML): These are set based on the toxicological profile of individual substances.
• Overall Migration Limits (OML): The total non-volatile substances migrating from the adhesive into food is capped at 10 mg/dm².

Compliance and Safety Measures

Labeling and Identification

Adhesive products must clearly label whether they are intended for direct or indirect food contact, ensuring that downstream users can make informed decisions.

Manufacturer Responsibilities

Manufacturers must implement comprehensive safety management systems covering the entire production process, from raw material selection to final product testing.

Impact on the Food Industry

The implementation of GB 4806.15-2024 will significantly impact both domestic and international food manufacturers exporting to China:

• For Domestic Manufacturers: The standard represents stricter regulatory oversight, likely requiring investments in new equipment and quality control measures.
• For International Manufacturers: Those exporting to China must ensure their adhesives comply with GB 4806.15-2024, possibly requiring reformulation or additional testing.

Conclusion

GB 4806.15-2024 is a significant step forward in China’s efforts to enhance food safety. As the February 2025 enforcement date approaches, manufacturers must ensure compliance with these new regulations, which will ultimately lead to a safer and more transparent food supply chain.