Key takeaway
What This Development Means
China's mandatory GB 4806.10-2025 and GB 4806.16-2025 food-contact standards took effect on 2 September 2026. They update controls for coatings and coated layers and create a dedicated silicone-rubber standard, including a 0.5% volatile-substance limit. Manufacturers and importers should refresh specifications, migration testing, declarations and component-level compliance evidence.
Are GB 4806.10-2025 and GB 4806.16-2025 mandatory now?
Yes. Both standards were published on 2 September 2025 and implemented on 2 September 2026. Products within scope should now be assessed using the current texts and applicable general and component-specific food-contact requirements.
Does compliance with the silicone standard cover the whole article?
Not necessarily. Other components, including coatings, inks, adhesives and plastics, remain subject to their own standards. Manufacturers should assess the assembled article, intended food and use conditions, and interactions between materials when selecting tests and supporting documentation.
Source basis: GB 4806.10-2025 official standard record
China Food-Contact Standards Are Now In Force
China's new food-contact standards for coatings and silicone rubber took effect on 2 September 2026. The official National Digital Standards Library lists GB 4806.10-2025 and GB 4806.16-2025 as current mandatory national food-safety standards, published one year earlier.
The implementation date is the regulatory trigger. Manufacturers, importers and sellers should now assess products against the 2025 texts rather than continue relying on superseded specifications or the transition period.
What The Food-Contact Standards Change
GB 4806.10-2025 covers coatings and coated layers used in food-contact materials and articles, including coated paper and indirect food-contact applications within its definitions. It expands the permitted-substance framework from base resins to base raw materials and updates testing and labelling provisions.
Primary aromatic amines migrating into 4% acetic acid must be not detectable using the prescribed method, with a stated detection limit of 0.01 milligrams per kilogram. Special sample-preparation and testing considerations apply where metal-can coatings are damaged. Businesses must verify the exact simulant, time, temperature and article-use conditions before interpreting a result.
GB 4806.16-2025 creates a dedicated framework for food-contact silicone-rubber materials and articles, separating them from the wider rubber standard. It covers relevant silicone systems, including room-temperature vulcanising materials, and sets a volatile-substance limit of no more than 0.5%. Migration, potassium-permanganate consumption and heavy-metal requirements also apply according to the authorised text.
Component Compliance Remains Important
The new standards do not replace China's general GB 4806.1 framework or other material-specific rules. Inks, adhesives, coatings, plastics and other components used in a finished article must meet the standards applicable to them. A compliant silicone component does not automatically make the assembled article compliant.
Manufacturers should update bills of materials, positive-list checks, supplier declarations and test plans. Importers and brand owners should confirm that reports cover the current standard number and intended food-contact conditions. Laboratories should check method editions, detection capability and sample treatment. Distributors and retailers should retain conformity documents and create an escalation process for old or ambiguous reports.
Foresight analysis: the standards increase the importance of cross-component evidence. Products combining silicone, coatings, inks and adhesives can fail compliance governance even when each supplier provides a generic certificate, because the finished use conditions and interfaces determine the necessary testing.
Related Foresight coverage examines China's chemical industry standards for batteries, plastics and coatings, the product-safety topic and China's proposed GB 15258 chemical-safety label revision.
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