China Issues Revised Mandatory National Standard for Coatings Used in Food Contact Materials 
On September 2, 2025, China’s National Health Commission officially issued the revised version of the mandatory national standard titled “National Food Safety Standard: Coatings and Coating Films for Food Contact Materials and Articles” (GB 4806.10-2025). This revision updates the 2016 version and will come into effect on September 2, 2026. The 2025 version expands the scope to include coating films that come into indirect contact with food and introduces new requirements for coating manufacturers and users. Additionally, the number of permitted raw materials has significantly increased from 105 to 346, and a total migration limit for primary aromatic amines (PAAs) has been added.
Expanded Scope of Application
The 2025 version redefines “coatings and coating films for food contact materials and articles” as:
Coatings and the resulting coating films applied to food contact materials and articles that are either in direct contact with food or are expected to come into indirect contact with food, and whose components may migrate into food.
This definition explicitly includes coatings and coating films expected to come into indirect contact with food but still pose a risk of component migration.
New Requirements for Coating Manufacturers and Users
The 2025 version introduces provisions requiring coating manufacturers and users to control safety risks throughout the entire production and application process. Coating users are also required to minimize the amount and residue of coatings used, as long as the intended function is achieved.
Addition of Permitted Raw Materials
Annex A, which lists the basic raw materials permitted for use in coatings and coating films for food contact materials and articles, has been significantly expanded—from 105 substances in the 2016 version to 346 in the 2025 version.
New Limit on Migration of PAAs
The table of physicochemical indicators in the 2025 version includes a new requirement for the total migration limit of primary aromatic amines (PAAs). According to the table, PAAs must be “not detectable”, with a detection limit of 0.01 mg/kg.
Labeling Requirements
Labeling and marking must comply with GB 4806.1 “National Food Safety Standard: General Safety Requirements for Food Contact Materials and Articles.”
The official announcement of the standard (in Simplified Chinese) can be accessed at the following URL:
https://www.cqn.com.cn/zj/content/2025-09/26/content_9124925.htm
