| market | core standards framework | Priority verification path |
|---|---|---|
| CN China | GB 4806.1 stipulates the general safety baseline for food contact materials and products. ; Fiber substrates generally apply to GB 4806.8; food contact coatings and coatings generally apply to GB 4806.10, and need to be checked in conjunction with the current GB 4806 series requirements and transition rules. ; GB 9685-2016 is used to review additives, scope of use, limits and restrictions. ; GB 31604.1-2023 and related GB 31604 methods are used to support the test design of items such as total migration, specific migration, heavy metals, PFOS/PFOA and primary aromatic amines (PAA). | Migration test conditions are determined based on food type, contact temperature, contact time and surface area to volume ratio. ;Check the formula ingredients item by item with GB 9685 and applicable GB 4806 positive list or restriction requirements. ; Develop separate verification plans for paper cups, paper bowls, trays, hot drinks, fatty foods, microwave use and heat sealing conditions. ; If the statement "PFAS not intentionally added" is used, it should be accompanied by a screening report, method information and detection limit. |
| US USA | 21 CFR Part 176 applies to indirect food additives in paper and paperboard components. ;21 CFR 176.170 covers paper and paperboard components in contact with aqueous and fatty foods. ;21 CFR 176.180 covers paper and paperboard components in contact with dry food. ;Coatings, resins, additives, polymers and non-paper components may require further verification of Parts 175, 177, 178, or FCN, TOR pathways. ; The FDA has announced that PFAS oil repellents used in paper and cardboard food packaging are no longer sold for food contact use in the United States; the statement "PFAS not intentionally added" should still be supported by screening data. | First classify food types and usage conditions according to water-based, acidic, fatty, dry, hot filling, reheating or storage. ;Confirm that each component has applicable CFR listing, GRAS or prior sanction basis, FCN or other authorization path. ;Determine extraction, migration, residual monomers or non-intentionally added substances (NIAS) assessment based on the customer's actual use. ; Do not use the absolute “PFAS-free” statement before the method, LOD/LOQ and batch range are clarified. |
| EU European Union | Regulation (EC) No 1935/2004 sets out the principles of safety, inertness, traceability and documentation for all food contact materials. ; Regulation (EC) No 2023/2006 stipulates Good Manufacturing Practice (GMP) requirements. ; Regulation (EU) No 10/2011 manages plastic or synthetic resin layers through Union List, Overall Migration Limit (OML), Specific Migration Limit (SML), Declaration of Conformity (DoC) and supporting documents. ;Paper, board, coatings, inks and adhesives should be assessed in conjunction with material structure, EU measures, Member State requirements and customer specifications. | Create a material structure diagram covering fiber substrates, coatings, inks, adhesives, functional layers and food contact surfaces. ; Determines whether a plastic or synthetic resin layer triggers EU 10/2011. ; Overlay BfR XXXVI, Swiss regulations, French, Dutch or other member state requirements depending on the customer's target market. ;form DoC and supporting documentation and cannot rely solely on barrier performance data. |
| DE germany | EU 1935/2004 and EU 2023/2006 form the horizontal basis. ;BfR Recommendation XXXVI Applicable to paper, cardboard and molded fiber food contact materials, typically including serving and reheating conditions up to 90°C. ;XXXVI/1 involves thermal extraction uses such as tea bags, thermal filter paper and boiled bags. ;XXXVI/2 relates to baking and microwave use. ;XXXVI/3 relates to cellulose fiber absorbent pads. ; For composite, multi-layer or coated materials, the paper or cardboard layer on the food contact side shall comply with XXXVI, and other layers shall not cause harmful migration or sensory effects. | Choose XXXVI, XXXVI/1, XXXVI/2 or XXXVI/3 based on actual usage. ; Prioritize the evaluation of cold water extraction, lead/cadmium, aluminum migration, azo dyes, optical brighteners, PAA and other related projects. ;The BfR recommendations are not mandatory EU-wide regulations, but are generally considered an important safety benchmark for the German market. ;The BfR will no longer accept new PFAS substances, so projects should strengthen evidence of PFAS exclusion and screening. |
| CH Switzerland | FDHA Ordinance SR 817.023.21 manages materials and articles intended to come into contact with food. ; FSVO guidance states that substances in packaging may migrate into food and are therefore subject to regulation. ;Packaging inks should be checked against current Annex 10 listings and CMR or non-migration requirements; Annex 6 may still be referenced in older materials. ;Concern for evidence of non-migration of SML, PAA, pigments, nanoforms, and unevaluated substances. | First identify the ink, coating, adhesive, plastic layer and fiber functional layer. ;Check Annex 10 or other applicable checklist item by item. ; When using non-migration limits such as not detected or 0.01 mg/kg, the method and detection limit should be stated. ; An independent assessment of the Swiss market cannot be completely replaced by EU data. |
| JP Japan | Food Sanitation Act related standards cover general requirements, material-specific requirements, purpose-specific requirements and manufacturing requirements for utensils, containers and packaging. ; The Positive List system for synthetic resin raw materials has been implemented since 2020 and will be continuously updated. ;Synthetic resins include thermoplastics, thermosetting plastics and thermoplastic elastomers; rubber is not included. ; When non-synthetic resin materials such as paper or wood constitute the food contact layer, according to Q&A rules, the additional synthetic resin layer usually does not fall within the scope of PL; if the synthetic resin layer directly contacts food, a PL review is required. ;Chemically modified cellulose is incorporated into synthetic resin PL; Unmodified natural cellulose and regenerated cellulose are excluded according to Q&A guidelines. | Create a layer structure diagram: fiber substrate, coating, adhesive, ink and food contact surface. ; Determine whether the coating forms a continuous film layer; surface treatment agents that do not form a film can be further judged whether to exclude them based on Q&A logic. ;PL mapping by Table 1 base polymers and Table 2 additives. ; Exclusion from the scope of PL does not exempt operators from their responsibility for food hygiene and safety. |
| KR South Korea | The Food Sanitation Act sets out standards and specifications for utensils, containers and packaging. ; MFDS Standards and Specifications cover general requirements, material-specific specifications, test methods and limits. ; English MFDS information can be used for communication, but it still needs to be compared with Korean regulations and local customer or laboratory requirements. ;Fiber substrates, coatings, resin layers, printing, adhesives and food types should be identified for specific applications. | The English version can be used to establish a customer communication framework while retaining a review of the Korean terms. ; Select migration, heavy metals, residual monomers, evaporation residue and other related tests according to material category. ; Korean import customers may require verification from local laboratories or recognized methods. ; PFAS, fatty food contact, hot drinks and microwave use need to be stated separately. |
| AU Australia | The Australia New Zealand Food Standards Code applies to food sold in Australia and New Zealand. ;Standard 1.1.1 stipulates the structure and general provisions of the Codex, including food, packaging and import-related requirements. ; Food contact packaging, articles or materials should not be capable of being swallowed or causing a risk of obstruction if swallowed, nor should they be likely to cause injury, pain or discomfort. ;The current Chapter 1 no longer uses the old Standard 1.4.3 as the main path; historical data should be updated to Standard 1.1.1. | Building a food contact safety assessment around a customer's end product cannot rely on a single positive list. ; Prepare evidence of migration, odor and sensory effects, heavy metals, PFAS, NIAS or material safety. ; Packaging and labeling provisions may also apply to imported foods and should be consistent with the importer's information. ; When customers adopt AS/ISO, EU, BfR or FDA evidence, they should make it clear that it is a customer acceptance standard and is not automatically equivalent to the Australian legal path. |
| NZ new zealand | The Australia New Zealand Food Standards Code applies to related foods sold, processed, handled or imported in New Zealand. ;Standard 1.1.1 stipulates basic safety requirements for packaging and contact materials, and involves imported food packaging. ; Projects should also confirm additional requirements from local importers, brands, regulatory agencies or laboratories. ;EU, BfR or FDA evidence should be positioned as supplementary evidence and cannot be expressed as a New Zealand statutory positive list. | Use the ANZ Code as a baseline to confirm its applicability to New Zealand import or sales scenarios. ; Summarizes material safety, migration, PFAS, heavy metals, odor/sensory and customer specification evidence. ; Compostable, recyclable and repulpable claims should be verified separately from food contact compliance. ;Confirm whether the New Zealand importer requires local laboratory testing or third-party legal review. |