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Breaking News: China's CFSA Publishes Implementation Guidance on GB 9685-2016

On June 1, 2017, China's National Center for Food Safety Risk Assessment (CFSA) published a guidance book on the implementation of GB 9685-2016. This guidance book, titled GB 9685-2016 <Food Safety National Standard - Standard on the Uses of Additives in Food-Contact Materials and Articles> Implementation Guidance,[1] is written in Chinese and has over 300 pages. It includes six chapters and four appendices:
  • Chapter 1 - Overview, which briefly introduces the history, status and role of GB 9685 standard;
  • Chapter 2 - Standard Amendment Summary, which talks about the background, principle, and overall process of GB 9685 amendment, as well as the major revision in the 2016 version;
  • Chapter 3 - Standard Content Description, which discusses each section of GB 9685-2016;
  • Chapter 4 - Overview of China's Food-Related Product Management, which explains the management of food-related products in China and the system of standards for food-related products;
  • Chapter 5 - Overview of Regulations of Food-Contact Materials in Foreign Countries, which introduces the food-contact regulations in the U.S., EU, Japan, Canada and South Korea;
  • Chapter 6 - Overview of Risk Assessment of Food-Contact Materials in Foreign Countries, which talks about the risk assessment of food-contact materials in the aforementioned foreign countries except South Korea.
  • Appendix 1 - full text of Management Rules for the Administrative Approval of New Varieties of Food Related Products;
  • Appendix 2 - full text of Rules for the Petition and Acceptance of New Varieties of Food Related Products;
  • Appendix 3 - an English index of additives listed in GB 9685-2016;
  • Appendix 4 - new food-related products approved by NHFPC.

Keller and Heckman LLP is in the process of getting a hard copy of the Implementation Guidance and will provide further information on this GB 9685 guidance shortly. As previously mentioned, GB 9685-2016 will become effective on October 19, 2017.

In the meantime, should you have any questions regarding GB 9685, or any other food packaging standards in China, please do not hesitate to contact David Ettinger ( or Chen Hu ( at Keller and Heckman's Shanghai Representative Office, or your ordinary contact at Keller and Heckman LLP.

Keller and Heckman LLP is a global law firm founded in 1962. The Shanghai office opened in 2004, focusing on serving its global clients in the Asia Pacific Region regarding compliance matters from food and drugs, food packaging, cosmetics, consumer products, chemicals, medical devices to E-cigarettes and tobacco related products.

The firm's global food and drug practice has gained recognition by Chambers and Partners Asia-Pacific Guide in the category of Life Sciences (International Firms) - China. David Ettinger, the Shanghai office's chief representative, has attained noted practitioner status in the same category and guide.

[1]《GB 9685-2016食品安全国家标准  食品接触材料及制品用添加剂使用标准》实施指南