Flint Group Perspective: Navigating China’s Updated Food Contact Regulations

04 Dec 2025

At Flint Group, we’re committed to keeping our partners and customers up to date on evolving regulations and how they will be affected. This includes recent changes in China relating to coatings for use on food contact materials (FCMs).

New standards for food-contact coatings

Earlier this year, China’s National Health Commission (NHC) announced an extensive revision of its FCM framework, releasing 32 new national food safety standards and several amendments on September 25, 2025. Two of these directly affect coatings and related materials used in food packaging:

  • GB 4806.10-2025 (Paints and Coatings for Food Contact Materials and Articles)
  • GB 4806.16-2025 (Silicone Rubber Materials and Articles for Food Contact)

Both standards will take effect on September 2, 2026, with a one-year transition period for industry adaptation.

Major Technical Changes in GB 4806.10-2025

The newly revised GB 4806.10-2025 standard introduces important updates for coatings used with food contact materials.

  • The exclusion for paper coatings has been removed, and the regulation now applies to coatings for indirect food contact that include components with potential for migration.
  • The number of approved basic raw materials for FCM inks and coatings has grown from 105 to 346 substances, reflecting a major shift toward a more comprehensive positive list approach.
  • The specific migration limit for Bisphenol A (BPA) has been reduced tenfold, from 0.6 mg/kg to 0.05 mg/kg.
  • Requirements for Overall Migration, Potassium Permanganate Consumption, and Heavy Metals (as Pb) now apply only to coatings that directly contact food.
  • Standards for the Total Migration of Primary Aromatic Amines (PAAs) have been added, further strengthening consumer safety requirements.

Why this matters to the industry

With enforcement beginning in September 2026, compliance with GB 4806.10 is a legal prerequisite for market access in one of the world’s largest consumer markets. Beyond risk mitigation, proactive compliance ensures business continuity and safeguards supply chains.

Flint Group’s perspective

We recognise the importance of regulatory compliance as a cornerstone of trust and business continuity. A broad portfolio of Flint Group products already meets the requirements of the updated GB 4806.10-2025, and our teams continue to validate and enhance formulations to align with new safety criteria.

 

For more information or questions about specific products or materials in scope, please contact your regional sales representative.