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Food Contact Materials (FCM) Migration Test

When it comes to food contact materials and articles, there’s a possibility that their components and additives may migrate into the contacted food. Should these substances contain toxic or harmful elements, it could have adverse impact on human health.

As outlined in Article 52 of the Food Safety Law, manufacturers of food-related products are required to conduct inspections on the food, food additives, and related products in accordance with food safety standards. Only after passing these inspections can these products be released for distribution or sale.

What is the Definition of Migration Test?

Tests conducted under specific conditions to determine the migration of components from food contact materials and articles (FCM) into the food or food simulants they come into contact with.

It’s stipulated that:

  • According to Section 3.1 of GB 4806.1-2016, the amount of substances migrating from food contact materials and articles into foods under recommended conditions of use shall not cause harm to human health.
  • According to Section 4.1 of GB 4806.1-2016, the total migration, usage level, specific migration, specific total migration and residue level of food contact materials and articles shall comply with the requirements in relevant national food safety standards regarding the total migration limit, maximum usage level, specific total migration limit and maximum residue limit.

Laws and Regulations Related to FCM Migration Test

  • Food Safety Law of the People’s Republic of China;
  • GB 4806.1-2016 General Safety Requirements for Food Contact Materials and Articles;
  • GB 31604.1-2015 General Rules for Migration Test of Food Contact Materials and Articles;
  • GB 31603-2015 General Manufacturing Hygiene Practices for Food Contact Materials and Articles;
  • GB 5009.156-2016 General Rules for the Migration Test Pre-treatment Methods of Food Contact Materials and Articles;
  • GB 9685-2016 Standard for the Uses of Additives in Food Contact Materials and Articles;
  • GB 4806.X-2016 Product Standard for Food Contact Materials and Articles; and
  • Other relevant notices.

News Updates

On September 25, 2023, China's National Health Commission (NHC) released the announcement No. 6, 2023 regarding 85 national food safety standards, including the GB 31604.1-2023 - General Principles for Food Contact Materials Migration Tests. This new standard, which will takes effect on September 6, 2023, is set to replace the existing GB 31604.1-2015. More details can be found here.

What are the Processes of FCM Migration Test?


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  • Compliance review of the FCM formula;
  • Consultation and training on the latest FCM regulations; and
  • Professional migration tests and national standards tests.