GB 4806.11-2023 Standard Interpretation
1. Background of Standard Revision
GB 4806.11-2023 is a comprehensive revision of the old version of "National Food Safety Standard Food Contact Rubber Materials and Products" (GB 4806.11-2016), and also replaces the former National Health and Family Planning Commission's Announcement No. 14 and related standards. This revision focuses on solving the following problems:
- The scope of rubber materials and products has been adjusted
- The migration test requirements and physical and chemical indicator system have been improved
- Technical restrictions on specific substances (such as N-nitrosamines) have been added
II. Comparative Analysis of Standard Frameworks
Items | Requirements of the 2016 version | New/modified content of the 2023 version |
Scope Definition | Food additive contact scenarios are not clearly involved | Clear provisions on food additive contact have been added |
Migration test conditions | Using vegetable oil as a food simulant | Added ethanol solution as an alternative, and relaxed restrictions on use in specific scenarios |
Physical and chemical index requirements | Not fully covering the detection of trace substances such as N-nitrosamines | Increased strict restrictions on the total migration of aromatic primary amines and N-nitrosamines |
III. Detailed explanation of technical requirements
1. Raw material management and safety specifications
GB 4806.11-2023 clarifies the basic raw material usage specifications for rubber materials:
- Natural rubber and synthetic rubber must comply with Appendix A and the provisions of the announcement
- Vulcanized thermoplastic elastomers must comply with the requirements of GB 4806.7-2023
- The use of additives must comply with GB 9685 and its announcement requirements
2. Sensory and physical and chemical indicators
Table 1 and Table 2 specify the sensory requirements and general physical and chemical indicators in detail:
Item | Indicator requirements | Test method |
Total migration amount*/(mg/dm²) | ≤10 | GB 31604.8 |
Potassium permanganate consumption/(mg/kg) | ≤20 | GB 31604.2 |
3. Migration test requirements
Migration tests are divided into general requirements and special requirements:
- Food simulants containing fats and oils must be vegetable oils. When the technology is not feasible, 50% ethanol solution can be used
- Specify the total migration test conditions under different use temperatures and times (see Table 3)
- Potassium permanganate consumption test requires three independent migration tests
IV. Implementation Recommendations and Compliance Paths
1. Material Selection and Procurement
Enterprises should:
- Give priority to basic raw materials that meet the requirements of Table A.1
- Strictly review the list of additives used to ensure compliance with the requirements of GB 9685
- Establish a qualification review mechanism for raw material suppliers
2. Quality Inspection and Verification
Recommendations:
- Establish an internal physical and chemical index testing laboratory equipped with professional equipment (such as HPLC, GCMS)
- Perform migration tests and sensory index monitoring regularly
- For specific substances (such as aromatic primary amines, N-nitrosamines), select professional institutions to conduct trace analysis
3. Labeling and identification management
Notes:
- Must indicate "the product contains natural latex" or similar warnings (if applicable)
- Label information must comply with GB 4806.1, including production date, shelf life, etc.
- It is recommended to provide a compliance statement and a summary of migration test results in a prominent position on the packaging
4. Training and system optimization
Enterprises should:
- Regularly organize employee training, focusing on interpreting the new standard changes and implementation requirements
- Establish a complete food safety management system (such as HACCP) and incorporate standard requirements into system documents
- Introduce digital management tools to monitor compliance indicators in the production process in real time