China Food Packaging Law
June 15, 2016
China's NHFPC Publishes Approvals for 23 Food Packaging Materials

On June 8, 2016, China's National Health and Family Planning Commission (NHFPC) announced online that 23 food packaging materials had passed the safety evaluation review by the NHFPC expert panel.[1] Specifically, the announcement includes final clearances for the following:
  • 12 new food packaging additives (Table 1),
  • 5 expanded use clearances for food packaging additives (Table 2),
  • 6 new food-contact resins (Table 3)
These approvals will ultimately be incorporated into the relevant Food Safety Standards. Specifically, the additive approvals will be added to China's GB 9685
Standard for Uses of Additives in Food Containers and Packaging Materials.[2] Meanwhile, the new plastic resin approvals will be incorporated into the new Standard on Food-Contact Use Plastic Resins.[3] It is doubtful that these approvals will be adopted in the Standards currently under revision. In all likelihood, they will remain administrative approvals until the Standards are next amended in the coming years.[4] This is merely a clerical issue, as these administrative listings are final approvals that may be relied upon to lawfully market the referenced food-contact materials in China.

The June 8 announcement follows NHFPC's April 29, 2016 release of its first batch of final approvals in 2016,[5] which included the following:
  • 15 new food packaging additives (Table 1),
  • 2 expanded use clearances for food packaging additives (Table 2),
  • 6 new food-contact resins (Table 3)
Both sets of approvals took considerably longer than usual, and this is likely due to the fact that the Chinese authorities have been busy implementing the recently amended Food Safety Law,[6] and developing/amending key Food Safety Standards. Given the proximity between these recent announcements (April and June), it appears that the pace at which Chinese food-contact approvals are issued will revert back to the timeframe that we have seen prior to 2015. More specifically, after a draft 
clearance is published, it typically takes approximately 6 months for NHPFC to publish the corresponding final approval.
David Ettinger
Wilfred Feng
Jenny Li
Mark Thompson
To Contact
The Bund Center
Suite 3604
222 Yan'an Dong Lu
Shanghai 200002
P.R. China
Phone: +86 21 6335 1000
Fax: +86 21 6335 1618

Keller and Heckman's Shanghai Representative Office has extensive experience assisting clients in obtaining clearances for food-contact substances in China. With specific regard to the April approvals, Keller and Heckman assisted with more than half of these filings. Should you have any questions concerning the petitioning process of food packaging materials in China, please don't hesitate to contact us or your contact at Keller and Heckman LLP. 

[1]        See NHFPC Announcement No. 7, 2016, available at
[2]        The current draft amendment was published by the NHFPC on January 20, 2015.  See NHFPC Announcement No. 18, 2015, available at  An article describing the draft amendment to the GB 9685 Standard is available on our website at
[3]        The current draft Standard was published by the NHFPC on September 29, 2015.  See NHFPC Announcement No. 803, 2015, available at  An article describing this and other draft packaging Standards is available on our website at  
[4]          Generally GB Standards are revised every 5 years.  However, depending on a given Standard's priority, such revisions may be more or less frequent.
[5]        See NHFPC Announcement No. 5, 2016, available at
[6]        See "China Passes Sweeping Amendment to Food Safety Law: The Most Stringent To Date," available at

"China Regulatory Matters" (CRM) is an e-newsletter prepared by the Shanghai Office of Keller and Heckman LLP. CRM is intended to update you in a timely manner on any significant Chinese regulatory changes in the areas of food, food packaging, cosmetics, environmental, and chemical control.
Shanghai Office

Keller and Heckman LLP established an office in Shanghai to meet the rising demand for global regulatory advice from companies operating in Asia. By combining a thorough understanding of trade and regulatory policymaking with expertise on the region's diverse laws and regulations, we assist clients in developing global best practices and meeting regulatory requirements to market their products throughout Asia. For more information, click here.