For example, additives used in printing inks in direct contact with food must be food additives permitted in China under GB 2760 on the use of food additives, whereas for indirect contact with food, the additives in printing inks must be food-contact additives cleared in GB 9685 on the use of food-contact additives or relevant government approvals. The draft standard establishes residual limits on heavy metals (lead, mercury, cadmium, chromium, and arsenic) in printing inks; it also sets out specifications on overall migration, potassium permanganate consumption, heavy metals (as Pb), and the migration level of primary aromatic amine for printing ink layers.
Food-Contact Use Paper and Paperboard
This draft paper standard will revise and replace the current GB standard on paper and paperboard (GB 4806.8-2016). Compared with the current version, it removes from the physicochemical specifications potassium permanganate consumption and heavy metal limits but adds residual limits on 1,3-dichloro-2-propanol and 3-chloro-1,2-propanediol. Other specifications on lead, arsenic, fluorescent substances, and formaldehyde remain unchanged and apply to paper and paperboard except those in contact with food that should be peeled, shelled, or washed before eating, cooking, or processing.
Food-Contact Use Bamboo and Wood Materials and Articles
This draft standard defines bamboo and wood materials and articles as those using bamboo, wood, or cork as raw materials, including cork stoppers, plant fiberboard containers, etc. Compared with the previous draft standard on "bamboo, wood, and cork materials and articles" published in 2016, the new draft standard makes revisions on various physicochemical specifications. For example, substances subject to residual limitations are reduced from six to four, but all with lower limitations than the previous draft. On the other hand, although the draft standard retains microorganism limitations, it makes it clearer that these limitations are applicable only to microorganisms in bamboo and wood materials and articles that are expected to come into direct contact with food and that can be directly used without disinfection or washing, except those in contact with food that should be peeled, shelled or washed before eating, cooking, or processing. Detergents
This draft standard will revise and replace the existing GB standard on detergents (GB 14930.1-2015). As in the current version, the draft standard categorizes detergents into two classes: Class A detergents are those used directly for washing food, whereas Class B are those used to wash food-contact utensils, tools, equipment, food packaging materials, and containers, etc. The major changes include a new positive list of raw materials permitted for use in Class A detergents (Appendix A) and the addition of limitations on 1,4-dioxane. Particularly, the Appendix A positive list of raw materials for Class A detergents explicitly lists 115 substances; various salts as well as acids of certain listed substances, substances listed on China's food additive standard (GB 2760), conventional food ingredients, etc., also are permitted. When Class B detergents use raw materials not in Appendix A, the manufacturer must conduct a safety assessment to make sure the residual or migration level of these substances may not endanger human health; however, preservatives and colorants used in Class B detergents must be permitted in Appendix A. * * * The period for public comment on these draft GB standards will end on November 30, 2020. Should you wish to learn more details about these draft standards and/or would like us to file comments to the Chinese authority on your behalf, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Chen Hu (hu@khlaw.com), Eric Gu (gue@khlaw.com), or your existing contact at Keller and Heckman LLP.
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