Q3: for composite paper (such as cake holder), the surface of food contacted with food is aluminum foil. Should we arrange the test according to the standard of GB 9683 composite packaging bag or the standard of GB 4806.9 metal material?

Interpretation: at present, there are GB 9683 "Hygienic Standards for composite food packaging bags" for the control of composite materials. However, the products targeted by this standard have certain limitations and are applicable only to food packaging bags made of paper, plastic film or aluminum foil through adhesives (polyurethane and modified polypropylene). The premises refer to composite paper not strictly within the scope of GB 9683.

It is suggested that if it belongs to the composite packaging bag in the scope of GB 9683, it can be tested according to GB 9683; otherwise, it should comply with the relevant regulations of GB 4806.1 general safety requirement 4.2.2 for composite materials, and all kinds of materials and materials in the composite materials meet the requirements of corresponding national standards, that is to say, it should not only meet the requirements of GB 4806.8 paper products, but also meet the requirements of GB 4806.9 metal materials.

Q4: the new GB draws heavily on the management concepts and methods of EU food contact regulations, so the products have already met the requirements of EU food contact materials and are also meeting the requirements of the new GB at the same time.

Interpretation: Although the new GB draws on the EU's management concepts and methods for food contact materials, the requirements for control and control of specific materials, testing conditions and maximum allowable limits are not exactly the same. For plastic molding products, the new GB has the requirement of Potassium Permanganate consumption, but the EU does not control the project. Therefore, products that have already met the requirements of the EU do not necessarily meet the requirements of the new national standard. It can also provide multinational food material compliance assessment and testing services at the same time, helping enterprises fully meet the requirements of different laws and regulations and different buyers.

Q5: can plastic particles be detected before they are tested?

Interpretation: for different testing items, the requirements for inspection are different. For example, migration test must be made of sheet or finished product, and dry weight loss and ignition residue can be detected by granular material.

GB 4806.7 plastic standard points out that the migration test should be carried out according to GB 31604.1 and GB 5009.156. GB 31604.1 "general rules for the migration test of food contact materials and products" 3.6 clearly stipulates that food contact materials (such as resins or granules, coatings, inks, adhesives, etc.) that are significantly different from the actual molded products shall be made in accordance with the actual processing conditions to make the molding products (or chips and samples) for migration tests.

The dry weight loss and ignition residue items come from the requirements of GB 4806.6 food contact plastic resin for related resin monomers. They should be tested according to the existing standards. Taking into account the particularity of test items and testing methods, they can be directly tested with plastic particles.

Q6: making products of different specifications and uses the same raw materials. If one of the products meets the requirements of the new national standard product of the food grade contact material, does it represent all other specifications of the products?

Interpretation: No.

The compliance of food contact products is related to the material, shape and conditions of use. For example, stainless steel materials are made into wok and electric kettle respectively. The food simulants are different in different food types. The specifications of similar products vary with the area volume ratio (s/V) of food contact, and the testing conditions for physical and chemical indicators are different. Therefore, even with products of different specifications and uses, there may be a product that meets the requirements and the other product does not meet the requirements. Therefore, it is recommended that every product of the enterprise be sent separately.

Q7: should food contact be identified on every part of the rice cooker?

Interpretation: "food contact" can be identified on the main body of the final product. 　　

GB 4806.1 general safety requirement 8.5 clearly stipulates that the final products of food contact materials and products should also be marked with "food contact", "food packaging" or similar words, or add and print the signs of spoonful chopsticks. That is to say, the main body of product information annotation should be the final product.

Q8:GB4806.1 8.4 requires the declaration of identity compliance, which will be implemented in October 19, 2017. As a raw material supplier, how to provide compliance statement? Is there a corresponding template for compliance statement?

Interpretation: when GB4806.1 comes into effect, raw material suppliers should prepare DoC and product identifier to pass relevant restriction information to downstream. At present, the national standard does not specify the format of the declaration of conformity, which can be decided by the production enterprise itself, but must include the following laws and regulations, the list of substances with restricted requirements, the restrictive requirements and the compliance of the total transfer volume. If intellectual property rights are not protected and material information is inaccessible, a qualified third party laboratory can also be verified. The guide for food supply chain responsibility and compliance statement of plastic food contact materials, prepared by the Expert Committee on food contact materials of China Food Industry Association, can be used as a reference for enterprises to prepare compliance statement.

Q9:GB4806.9 food contact metal standard 5.3.2 should specify the material type and material composition of the top metal substrate, or according to our national standard or uniform numeric code, which standards do these brands or uniform numeric codes have?

Interpretation: the new GB requires that all metal materials should conform to the information of GB4806.9, such as marking substrates, coating and so on. The law enforcement agencies will check the conformity of material composition and identification according to the corresponding standards and decide whether or not compliance.

In 2011, the Health Planning Commission pointed out that the relevant stainless steel plate standard (GB/T 3280) made provisions for stainless steel grades. The stainless steel products of the national standard for food safety stipulates that the main material of stainless steel products should be materials that conform to relevant national standards, that is, materials and brands that conform to GB/T3280.

In the production practice, there are also enterprises in accordance with the GB/T 20878 "stainless steel and heat resistant steel grades and chemical composition" for stainless steel grade marking and chemical composition analysis, but GB/T 20878 for certain stainless steel composition content is not exactly the same as GB/T 3280, for example, for brand S30408 stainless steel, GB/T 3280 and GB/T 20878 for element carbon (C), nickel (Ni) and chromium (Cr) content requirements are different, hicko detection recommends that enterprises try to follow GB/T 3280 to carry out stainless steel brand marking and ingredient analysis.

GB/T 3190 specifies the grades and chemical composition of wrought aluminum and aluminum alloys.

Q10: how do we choose the simulants and temperature and time for the migration test of food contact products under the new national standard?

Interpretation: GB 31604.1 "general regulations on food safety national standards for food contact materials and products migration" stipulates the selection principles of temperature and time for food simulants and migration tests.

The choice of food and food simulants included in Appendix A of this standard should be in accordance with the appendix. Food that is not included in Appendix A is selected as a simulant for migration test according to the type of food that is expected to be contacted (water, alcoholic beverages, oily food, etc.). 10% or ethanol, 4% acetic acid, 20% ethanol, 50% ethanol, and vegetable oil are selected as one or more of them. Of course, product standards (such as GB 4806.3-2016, GB 4806.4-2016, GB 4806.5-2016, GB 4806.9-2016, GB4806.11-2016, etc.) have special provisions. Priority should be given to the choice of simulants and testing conditions according to product standards.

For testing temperature and time, reference should be made to the relevant requirements in GB 31604.1 according to the expected conditions of use. For those unspecified requirements, the most stringent test conditions should be chosen with scientific support.

In addition, if the product can be reused, it will affect the procedures and times of the migration test. Therefore, when sending food contact products, the enterprises should at least provide information such as product quality, reusable, expected food type, contact temperature and time, so that we can more accurately recommend test items and migration test conditions.