Food safety is a significant concern worldwide, with different countries implementing various regulations to ensure the safety and health of their consumers. China, known for its vast and complex food industry, has stringent regulations concerning food additives. This blog post explores the landscape of banned food additives in China, highlighting why certain additives are forbidden and the implications of these regulations.
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Food additives are substances added to food to enhance its flavor, appearance, or preservation qualities. These include colors, stabilizers, preservatives, and flavor enhancers, among others. While many additives are safe, some have been found to be harmful to health, leading to restrictions or bans.
In response to food safety scandals and public concern, China has established comprehensive food safety laws. The principal regulations governing food additives include:
These laws are enforced by the China Food and Drug Administration (CFDA), which is tasked with regulating food additives, overseeing their safe use, and updating the list of permitted and banned substances.
China has banned several food additives due to health concerns. These substances have been linked to diseases and health conditions such as allergies, hyperactivity, and even cancer. Here are some notable examples:
A synthetic dye used previously to enhance the color of chili powder and other foods. It is carcinogenic and has been completely banned in food products.
This additive is used to increase the volume and lighten the texture of bread. It has been found to cause cancer in animals and has been banned in China since .
These are red dyes that were once used in chili and curry powders. They are carcinogenic and have been banned from use in foods since .
Rongalite is a bleaching agent that was used in flour and candy. It has been banned due to its potential toxic and carcinogenic effects.
Once used as preservatives, these compounds have been banned in food production due to toxicity.
The prohibition of these food additives underscores China’s commitment to food safety and public health. By banning harmful additives, the CFDA aims to prevent health risks associated with toxic substances. The bans also align China’s food safety regulations with international standards, helping to improve the global perception of Chinese food products.
Despite stringent laws, China faces challenges in enforcing these bans effectively. The vastness of the country and the sheer scale of its food industry mean that illegal use of banned substances still occurs. Regular food safety incidents highlight the ongoing struggle to monitor and control the food supply chain.
For consumers in China and those purchasing Chinese products internationally:
China’s ban on certain food additives is a positive step towards enhancing food safety and protecting public health. While challenges in enforcement remain, these regulations are crucial in preventing the use of harmful substances in foods. As consumers, staying informed and vigilant is the best strategy to navigate this landscape.
Updated in Aug
Food contact materials are usually defined as materials and articles which are intended to come into contact with food, such as packaging materials, cutlery, processing machines and containers, etc. However, different countries or regions may have different definitions/ names for these materials:
In China, food contact materials (FCMs) are regulated by China Food Safety Law issued in . The Article 32 & 62 of China Food Safety Law prohibits the importation, use or purchase of food-related products (e.g., food additive, food packaging materials) not complying with applicable Chinese Food Safety Standards. There are currently over 130 National Standards & 125 Industry Standards for food package materials & containers in China and they set specific safety requirements (evaporation residue, migration of hazardous) on FCMs from three levels:
Some examples of those main standards are listed as follows:
What is New?
12 Nov , A Preview of China's Plan to Revise Its Food Contact Standards. More info can be found here.
The main safety concern of food packaging materials is in the possible migration of hazardous substances from the actual packaging materials into the different types of food contained within (acidic food, fatty food, non-fatty food, etc). There are different risk substances for different material groups. For example, for stainless steel products, the migration of heavy metals is the main concern. For FCMs made of polymer, monomer residue or migration of food additives can be main concerns. Finished articles usually need to be tested with appropriate food stimulants related to real use conditions (type of food, temperature) to demonstrate compliance. Chinese food safety standards have set specific testing requirements on different types of material groups or specific products to ensure safety.
For example, GB - Food Safety Standard for stainless steel products has required the following testing items:
Heavy Metals
SML（mg/dm2)
铅/Pb
0.01
铬/Cr
0.4
镍/Ni
0.1
镉/Cd
0.005
砷/As
0.008
Unlike Europe, Good Manufacturing Practice (GMP) is not compulsory for food contact materials in China. However, QS (quality safety) certificates are required for local manufacturers who produce food packaging materials made of plastics and paper. The General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) is the main body for enforcing food safety standards in China. Local manufacturers who do not have the QS certificates from AQSIQ are not allowed to produce and sell the food containers/packaging products. To get this QS certificate, manufacturers need to apply to the local AQSIQ agency. AQSIQ will then conduct an audit of the applicants production process and sites, do some sample testing and request a compliance statement and so on before issuing a QS certificate.
The most important food safety standard for food contact additive in China is GB - Hygienic Standard for Use of Additives in Food Containers and Packaging Materials and it includes 959 food contact additives (including monomers). China GB - sets out a positive list of food contact additives in China and additional limits such as SML (Specific Migration Limit) and QM (Maximum Quantity allowed).
One example is given as below:
GB defines food contact additives as the substances added to improve or assist to improve the quality and property of food containers and packaging materials to meet the expected purpose during the process of production; the assistants added in the process of producing food containers and packaging materials to help the smooth production but not to improve the quality and property of final products are also included. Since GB does not differentiate direct or indirect contact, many inks or adhesives to be used in food packaging materials and not intended to be indirect contact with food are also affected by this standard.
When the standard was issued in , it received strong complaints from industry because many other food contact additives that had been approved in EU & USA or proved to be safe were already placed on Chinese market and were not yet included in the standard. To cope with this, the MoH and other ministries jointly issued a circular in allowing industry to petition by 1 June the Institute of Nutrition and Food Safety (INFS) for the listing of substances not yet listed on GB- or other Chinese standards which are safe for contact use. This is called ‘Grandfathering Process’. As a result of this process, the MOH reviewed submitted petitions, approved more food contact additives in several batches and expanded the positive list from 959 substances to more than 1,500 food contact additives.
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The update history of the positive list of food contact additives is listed as follows:
Year of Issue
Regulation or Notice
No. of food contact additives approved
MOH Notice -126
4(Draft)
MOH Notice -8
4
MOH Notice -168
1(Draft)
MOH Notice -5
258
MOH Notice -11
3
MOH Notice -5
301
MOH Notice -10
List of 107 Resins for FCMs
GB -
959
Many substances on Chinese positive list are from European positive list for contact additives and share the same SML or QM. However, there are several big differences between the positive lists in China and Europe.
China
Europe
Currently GB is being revised. The newly approved food contact additives will be added to GB to form a consolidated list. For those substances not on the positive list, the use in food containers and packaging materials is strictly forbidden unless food contact notification has been submitted and approved.
If you would like to get the English version of GB - and all lists of newly approved food contact additives, please complete this order form and send it to
In , the Ministry of Health (MOH) has published the Measures on Administrative Permission of New Varieties of Food Related Products and the measures have set detailed requirements on notification of new varieties of food related products (including new food packaging materials and new food contact additives). According to the measures, the following documents are required for food contact notifications.
It shall be noted that the required toxicology safety assessment data depends on the specific migration(SM). If the OM is very low, lots of toxicology data can then be exempted. According to MOH's draft guidance on approval of new food-related species, the following toxicoloy studies are required for food contact notification:
Since the publication of the measures in , 3 new food contact additives have been approved in the MOH’s notice -11 in accordance with the measures.
Initially set up by China Inspection and Quarantine(CIQ) Bureau in to provide REACH compliance services to Chinese chemical industry, CIRS has grown to be a leading provider of comprehensive chemical compliance services for companies doing businesses in/with China.
Our services for China include new substance notification, registration of the import and export of toxic chemicals, registration of hazardous chemicals, classification and labeling in according to China GHS, Chinese SDS, risk assessment of industrial chemicals, food additives, food contact materials and cosmetic ingredients. We provide one-stop solutions to your regulatory issues in China. We also deliver the most up-to-date regulatory information about chemical control laws in China. For food contact materials and food contact additives, we offer the following services:
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