China has issued a draft national food safety standard titled Food Safety National Standard Regenerated Cellulose Materials and Products Intended for Food Contact for public consultation, signalling a major regulatory move to strengthen oversight of regenerated cellulose materials used in food packaging and related applications. Once finalized, the standard will be implemented nationwide under the GB (Guobiao) National Standards system.
Scope and Applicability
The draft standard applies to regenerated cellulose materials and products intended for food contact under normal or reasonably foreseeable conditions of use. This includes materials that directly contact food, are designed to contact food, or whose components may migrate into food. Typical applications covered by the draft include regenerated cellulose films (commonly known as cellophane) used in food packaging and regenerated cellulose casings used in food processing.
Definitions and General Safety Requirements
The draft defines food?contact regenerated cellulose materials as products primarily made from natural cellulose that has been chemically dissolved and regenerated through industrial processes. These materials are required to be safe for consumers and must not pose risks to human health under their intended conditions of use.
At a fundamental level, all products covered by this standard must comply with GB 4806. Chinas general safety standard for food?contact materials and articles. This aligns regenerated cellulose products with the broader national framework governing food?contact safety, traceability, and compliance responsibility.
Raw Material and Additive Controls
Strict requirements are proposed for raw materials and additives:
1.Raw materials used in regenerated cellulose products must be non?hazardous to human health.
2.The use of additives must comply with GB 9685 and any relevant official regulatory announcements.
3.This provision is particularly significant for manufacturers, as regenerated cellulose production often involves chemical processing aids, plasticizers, and functional additives that require careful regulatory control.
Sensory Quality Requirements
The draft includes sensory (organoleptic) requirements to ensure product cleanliness and quality. Regenerated cellulose materials intended for food contact must:
1.Have normal colour
2.Be free from abnormal Odors
3.Show no Mold, stains, or visible foreign matter
In addition, migration test solutions obtained during compliance testing must not exhibit discoloration, turbidity, precipitation, or off?Odors, ensuring that contact with food does not cause perceptible quality deterioration.
Migration Limits and Physicochemical Standards
a) General Migration: The standard proposes a total migration limit of 10 mg/dm for regenerated cellulose materials used in food contact. This limit controls the overall amount of substances that may migrate from the material into food during use.
For materials intended for infant and young childrens food, the draft introduces more protective requirements. Migration results must be converted based on the actual surface?area?to?volume ratio in use, with a maximum allowable value of 60 mg/kg, reflecting stricter safety expectations for vulnerable populations.
b) Heavy Metals and Residual Substances
The draft establishes specific limits for heavy metals and residual contaminants, including:
Lead migration: not exceeding 1 mg/kg under specified acidic test conditions
Residual lead content: ? 1.0 mg/kg
Residual arsenic content: ? 0.1 mg/kg
These limits aim to minimize long?term exposure risks associated with cumulative heavy?metal intake.
Additive?Specific Migration Requirements
Beyond general migration controls, the draft requires compliance with specific migration limits (SML), total specific migration limits [SML(T)], and maximum residual quantities (QM) for substances regulated under GB 9685 and related administrative notices. This ensures tight control over individual chemical substances used in material production.
Additional Requirements for Coatings, Inks, and Adhesives
Where regenerated cellulose materials incorporate coatings, printing inks, or adhesives, these substances must independently comply with their respective food safety national standards. This requirement addresses common multilayer packaging structures and printed materials widely used in modern food packaging.
Testing and Labelling Provisions
The draft specifies that migration testing must be conducted in accordance with nationally recognized analytical methods to ensure consistency and reliability of results. In addition, labelling and identification requirements must comply with GB 4806.1, supporting traceability, regulatory supervision, and market compliance.
Industry Impact and Public Consultation
Once implemented, the standard is expected to bring higher compliance obligations for manufacturers of regenerated cellulose films, casings, and food?contact materials. Companies may need to strengthen raw?material selection, additive management, migration testing, and documentation processes.
Regulatory authorities have invited public and industry stakeholders to submit comments during the consultation period. Feedback from manufacturers, trade associations, testing organizations, and research institutions will play a key role in refining technical requirements before the standard is formally adopted
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