| At a Glance: China’s mandatory national food safety standards GB 4806.10-2025 (coatings and coated layers) and GB 4806.16-2025 (silicone rubber) took effect on September 2, 2026. The new standards introduce strict requirements, including limits on primary aromatic amines and volatile substances, requiring affected companies to immediately ensure full regulatory compliance. |
On September 2, 2026, GB 4806.10-2025, National Food Safety Standard — Coatings and Coated Layers for Food Contact Materials and Articles, and GB 4806.16-2025, National Food Safety Standard — Silicone Rubber Materials and Articles for Food Contact, officially took effect (published under Announcement No. 6 of 2025 as mandatory national standards).
CIRS Testing, a CMA- and CNAS-accredited third-party institution, now offers full-scope testing for all items under the new national standards. Our expanded capabilities include the recently added requirements for total migration of primary aromatic amines (GB 31604.52-2021) and volatile substances analysis.
1. Transition Period Ends — New National Standards Now Mandatory
The two standards were jointly issued by the National Health Commission and the State Administration for Market Regulation on September 2, 2025, and officially took effect on September 2, 2026. With the transition period now over, all coatings and coated layers, as well as silicone rubber food contact materials and articles, produced or sold from today onward must comply with the new standard — regulatory and e-commerce platform spot checks have also switched to the new standards for conformity assessment.
Standard No. & Title | Supersedes | Effective Date | Key Changes |
GB 4806.10-2025 Coatings & Coated Layers for Food Contact Materials and Articles | Supersedes GB 4806.10-2016 | 2026-09-02 | Paper coatings & coated layers included for the first time; new “not detectable” requirement for primary aromatic amines |
GB 4806.16-2025 Silicone Rubber Materials and Articles for Food Contact | Supersedes GB 4806.11-2016 (silicone rubber part) | 2026-09-02 | China’s first standalone standard for silicone rubber; new limit for volatile substances |
2. GB 4806.10-2025: Six Key Changes for Coatings & Coated Layers
Change | Key Points |
Broader scope of application | Paper coatings & coated layers on paper cups, paper bowls and paper food containers are covered for the first time (explicitly excluded under the previous edition); the scope now also covers indirect contact scenarios. |
★ Primary aromatic amines: “not detectable” | For coatings containing aromatic isocyanates (MDI/TDI), azo colorants and similar substances, the total migration of primary aromatic amines into 4% acetic acid must not be detectable (detection limit 0.01 mg/kg), tested in accordance with GB 31604.52-2021. |
Two-way risk management duties | Producers must control formulations and process parameters; users (e.g. canning and cookware plants) should control risks through seam/edge design, barrier layers and cure control, while minimizing coating usage. |
Raw material management adjusted | Annex A has been expanded from “base resins” to “base raw materials”; polymer-related substances with a molecular weight above 1,000 Da are permitted. Additives must still comply with GB 9685. |
Special rules for migration testing of metal cans | If coating detachment, blistering or corrosion occurs during the 4% acetic acid test, re-test using specimens prepared on an inert substrate; where this is not feasible, 10% ethanol may be used instead. |
Simplified labeling | The requirement to “indicate the material names of the substrate and the coating separately” has been removed; labeling now uniformly follows GB 4806.1. |
3. GB 4806.16-2025: Five Key Changes for Silicone Rubber
Change | Key Points |
First standalone standard for silicone rubber | Split off from GB 4806.11-2016 to apply exclusively to silicone rubber; the term “vulcanization by heating and pressurizing” has been removed, and room-temperature vulcanization and other processes are now covered. |
★ New: volatile substances ≤ 0.5% | Prevents low-molecular-weight siloxanes in baking molds and other articles from volatilizing and migrating at high temperatures; the determination method is given in Annex B. |
Stricter test conditions | Immersion time for the potassium permanganate consumption test and heavy metals (4% acetic acid, expressed as Pb) is extended from 60 °C/0.5 h to 60 °C/2 h, consistent with standards for plastics and other materials. |
Combined-process compliance requirements | Articles that use coatings, inks or adhesives must also comply with the corresponding standards — silicone rubber articles with printed patterns therefore require multi-standard compliance. |
Updated raw materials & labeling | Annex A has been revised into a list of base raw materials for silicone rubber; labeling uniformly follows GB 4806.1. |
4. Which Products Are Affected?
- Coatings & coated layers: Metal cans (food and beverage cans), non-stick pans and cookware coatings, inner liners of kitchen appliances, interior surfaces of food processing equipment, extrusion-coated paper cups/paper bowls, etc.
- Silicone rubber: Infant bottle teats, baking molds, silicone spatulas, spoons and placemats, cookware sealing rings, silicone straw cups, etc. Articles with printed patterns or composite coatings must also comply with the corresponding standards (multi-standard linkage).
5. Recommended Actions for Companies
- All products shipped from September 2 onward must comply with the new standards — take stock of your product lines involving coatings/coated layers and silicone rubber as soon as possible.
- Request formulation information and compliance statements aligned with the new standards from raw material suppliers, with priority screening of coatings based on aromatic isocyanate systems.
- Prioritize testing of the two newly added parameters — primary aromatic amines and volatile substances — which carry the highest risk of non-compliance.
- Update quality inspection reports and labeling information to the new standard versions in parallel, to avoid the risk of delisting on e-commerce platforms.
6. CIRS Testing: Full Testing Capability for Both New Standards
CIRS Testing is a wholly owned subsidiary of CIRS Group and a National High-tech Enterprise, accredited with both national-level and provincial-level CMA and CNAS qualifications. Its laboratories cover more than 10,000 m² and are equipped with major analytical instruments including LC-MS/MS, GC-MS and ICP-MS, having served over 30,000 companies in total.
Test Item | GB 4806.10-2025 Coatings & Coated Layers | GB 4806.16-2025 Silicone Rubber |
Sensory requirements / Overall migration | ✓ (GB 31604.8) | ✓ (GB 31604.8) |
Potassium permanganate consumption | ✓ (GB 31604.2) | ✓ (60 °C/2 h) |
Heavy metals (as Pb) | ✓ (ICP-MS) | ✓ (60 °C/2 h, ICP-MS) |
Primary aromatic amines, total migration ★ New | ✓ (GB 31604.52, LC-MS/MS) | — |
Volatile substances ★ New | — | ✓ (Annex B) |
Specific substances SML/SML(T)/QM | ✓ (Annex A & GB 9685) | ✓ (Annex A & GB 9685) |
Complementary one-stop capabilities: full GB 4806 series standards, GB 31604 series test methods and GB 9685 additive compliance, plus FDA, EU 1935/2004, LFGB, Korean and Japanese food sanitation regulations and other domestic and international standards — one laboratory, full coverage for both export and domestic markets.
The early stage after the two standards take effect is exactly the peak period for regulatory and platform spot checks. CIRS Testing has opened a green channel for new-standard testing — priority scheduling with all items tested in one go — helping companies obtain compliance reports quickly. For further information or business enquiries, please contact the CIRS Testing team. We are committed to supporting enterprises in achieving regulatory compliance and sustainable development. If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com. |
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