The deadline related to the GB 4806-10-2025 Standard for China is approaching: How Flint Group Packaging Solutions supports compliance.

As global food packaging safety regulations continue to evolve, China’s National Health Commission (NHC) and the State Administration for Market Regulation (SAMR) have jointly issued GB 4806.10-2025 (National Food Safety Standard Paints and Coatings for Food Contact Materials and Articles). Replacing the earlier 2016 standard, this update introduces stricter chemical controls, significantly expands the positive list of permitted basic raw materials, and sets clearer responsibilities across the packaging supply chain.

The standard was issued on 25 September 2025 and is scheduled to take effect on 2 September 2026, following a one-year transition period. Navigating these updated food safety requirements is essential for market continuity. Flint Group Packaging Solutions is deeply committed to maintaining continuous regulatory compliance, and we actively share our technical and regulatory expertise to help our partners navigate these changes seamlessly and with total confidence.

Key Regulatory changes:

1. GB 4806.10-2025 applies to coatings and coating layers used in food-contact materials and articles, including coatings intended for indirect food contact where substances from the coating could migrate into food under the intended conditions of use. Additionally, the standard harmonises controls for paper coatings, clarifying that coated paper and board products must comply with both GB 4806.8 and GB 4806.10-2025 requirements.

2. The list of permitted basic raw materials has grown from 105 substances in the 2016 release to 346 in the 2025 release. This offers formulators greater flexibility while simultaneously establishing clearer migration limits and specifications for newly included polymers and starting substances.

3. China’s authorities have tightened restriction parameters on critical chemical substances:

• Bisphenol A (BPA): The Specific Migration Limit (SML) for BPA has been reduced from 0.6 mg/kg to 0.05 mg/kg.
• Epoxy Derivatives & PAAs: Strengthened requirements have been introduced for epoxy derivatives such as BADGE, along with specific controls on the total migration of Primary Aromatic Amines (PAAs).
• Physicochemical Criteria: Standardised testing conditions for overall migration, heavy metals, and potassium permanganate consumption have been refined to ensure harmonised assessment across food contact testing laboratories.

4. Supply chain responsibility: GB 4806.10-2025 highlights shared safety risk control across the manufacturing value chain:

• Coating Manufacturers must manage safety risks through formula design, raw material selection, and accurate product information dissemination (e.g., Declaration of Compliance).
• Downstream Packaging Converters must ensure adequate curing, proper application density, and effective barrier performance to minimise migration risk.

Transition Period Ending Soon

GB 4806.10-2025 was published with a one-year transition window, making 2 September 2026 the mandatory effective date. “Beyond primary coating resins, we actively track developments around other GB 4806 and GB 9685 standards, including specific categories such as Printing Ink GB 4806.14, to help our partners navigate shifting regulatory expectations.” At Flint Group Packaging Solutions, we continuously analyse these evolving frameworks to guide our raw material evaluations and support our customers by sharing relevant technical insights. This helps our partners make informed decisions for their finished packaging applications.

As a leading global supplier, Flint Group Packaging Solutions is committed to supporting regulatory compliance throughout of the food packaging supply chain in all regions where it operates. While certain constituents may fall outside the specific listings of GB 4806, we fulfil our responsibility by providing the transparency necessary for a full safety assessment under GB 4806.1-2016. To enable downstream users to verify the conformity of the finished product, we provide detailed information regarding potentially migratable, reactive, or volatile substances via a Statement of Composition (SoC).