GB 4806.10-2025 Food Contact Coatings Testing

What Has Changed in GB 4806.10-2025?

GB 4806.10-2025 National Food Safety Standard - Coatings and Coatings for Food Contact Materials and Articles officially came into effect on September 2, 2026, replacing GB 4806.10-2016 as a mandatory national standard for food safety. The new standard significantly tightens specific migration limits for substances in coatings, as well as its physicochemical indicators and compliance requirements for 346 basic raw materials.

Expanded Scope of Regulatory Control

The standard defines coatings and coating films as materials intended to be applied to food contact materials and articles that directly contact food, or indirectly contact food with components that may transfer into food, along with the resulting coating (film). Coatings involved in indirect contact whose components may migrate are also under regulatory control.

This further expands the regulatory scope for food contact coatings and reinforces safety control across the entire supply chain:

1.Paper-Based Coatings: Removed the old exception for "not applicable to paper coatings." For the first time, it incorporates inner wall coating safety requirements for paper coating products such as hot drink paper cups, hamburger wrapping paper, and coated paper bowls/lunch boxes.

2.Metal/Composite Cans: Beverage can bodies/lids/pull tabs, thermos inner walls, and kitchen appliance inner liners.

3.Cookware Coatings: Non-stick pans, woks, and frying pans.

4.Indirect Migration Coatings: Coatings that do not directly touch food but may migrate (e.g., outer clear varnishes, inner lining coatings of equipment).

Strict Regulatory Controls

The new national standard enforces stricter regulations on potential interference substances, driving enterprises to optimize production processes, reduce harmful residue at the source, and deliver safer, more reliable products to consumers.

Post-Soaking Sensory Judgment: After soaking, there must be no cracking, blistering, or peeling off, and the soaking solution must have no off-odor, cloudiness, or precipitation.

Enterprise Compliance Action List

GB 4806.10-2025 was mandatorily implemented on September 2, 2026, replacing the relevant requirements of the 2016 version. Going forward, all coatings and coating films used for food contact materials and articles must meet the new national standard requirements. Non-compliant products are prohibited from production, distribution, and use.

1.Check Raw Materials: Cross-reference against the 346-item list in Appendix A to replace non-compliant resins and curing agents.

2.Update Labels: Remove the mandatory label requirement for "substrate + coating material" and align with GB 4806.1 labeling rules.

3.Re-Submit for Testing: Old test reports (2016 version) cannot cover production batches made after September 2, 2026.

4.Segment by Application Scenario: Conduct migration testing based on distinct conditions for cookware vs. drinkware.

With the implementation of the new standard, relevant companies are advised to conduct product evaluations and testing as early as possible to ensure a smooth transition, product compliance, and market access. As a third-party testing agency, JJR LAB provides FCM (Food Contact Materials) testing and certification services for food contact materials (coatings, plastics, metals, glass/ceramics, paper and paperboard, etc.) across China, EU, and US markets, paving the way for full regulatory compliance.