In the field of food flexible packaging, the GB 9685 standard for food contact materials is an unavoidable compliance baseline for all factories. It outlines the principles for the use of additives in food contact materials and products, specifies the types of additives allowed and their maximum usage levels, and directly affects whether packaging bags can be safely used for food. For buyers, understanding GB 9685 is equivalent to mastering the core criteria for assessing the professionalism of packaging suppliers. This article systematically breaks down the key points, testing methods, and implementation paths for enterprises from a factory operational perspective, helping you avoid common pitfalls when selecting food packaging bags.
What is GB 9685? Its position in the standard system
The full name of GB 9685 is “National Food Safety Standard for the Use of Additives in Food Contact Materials and Articles,” issued by the National Health Commission, and it is a mandatory national standard in the field of food contact materials. It, together with the GB 4806 series standards, forms the regulatory framework for food contact materials in China: GB 4806.1 outlines general safety requirements, GB 4806.6 to GB 4806.15 addresses specific materials (such as plastics, rubber, coatings, etc.), while GB 9685 focuses on the critical aspect of additives, answering three key questions: what can be used, how much can be used, and how to use them.
It should be noted that GB 9685 applies not only to plastics but also to inks, adhesives, coatings, and all materials in contact with food. Therefore, every layer of material, every drop of adhesive, and every printed ink in a composite packaging bag must comply with the requirements of GB 9685. This is the reason why compliance with multi-layer composite flexible packaging is more challenging.
Core requirements of GB 9685: Three principles for additive use
GB 9685 manages additives based on three fundamental principles. First is the permitted list principle: only substances listed in the annex of the standard may be used in food contact materials; substances not on the list are generally prohibited, referred to as a positive list management approach. Second is the principle of usage limits: each additive has a clearly defined maximum allowable usage level or specific migration limit. Third is the principle of migration control: the amount of additive migrating into food must not exceed the standard limit, ensuring consumer intake remains within a safe range.
For packaging manufacturers, this means that formulas are not decided on a whim. Whenever developing new structures or new formulas, the technical department must check each raw material against the list in GB 9685 and retain complete compliance documentation for each raw material, establishing a traceable compliance record.
How to Implement GB 9685 Compliance in the Factory: A Four-Step Practical Guide
The first step is raw material control. The factory should require all raw material suppliers to provide test reports and compliance statements conforming to GB 9685, and establish a raw material ledger. The second step is formula review. When developing new products, technical staff should check each additive in the formula against the standard list to confirm its allowable use and compliance with usage limits. The third step is finished product testing. According to the GB 31604 series testing methods, the finished products should be tested for total migration, specific migration, and other items to ensure that the actual product performance meets the required standards. The fourth step is document management. All related documents, including formula records, test reports, and supplier certificates, should be retained for regulatory inspections and customer audits.
It is worth noting that many buyers focus only on the “food grade certification” label on the finished product and overlook process compliance. A truly compliant factory should have a compliance system covering the entire process from raw materials, production, to testing, rather than just providing a single test report.
How can the buyer verify the supplier’s compliance with GB 9685?
As a buyer, you can verify a supplier’s compliance level from three levels. First, request test reports: ask the supplier to provide third-party test reports for the latest batch of finished products, focusing on key indicators such as total migration and heavy metals, and verify that the product name and material in the report match the product you are purchasing. Second, check raw material certificates: require the supplier to provide a GB 9685 compliance declaration for the raw materials used, and check whether their raw material system is complete. Third, conduct on-site audits: during your visit to the factory, inspect the laboratory setup, sample retention management, formula documents, and assess whether their compliance system is genuine or just superficial.
Be cautious, as some manufacturers use a single generic report to cover all customers, with the material and specifications on the report completely mismatching the actual product. This non-compliance risk, once triggered, will not only damage brand reputation but also endanger consumer health and safety.
Relationship Between GB 9685 and GB 4806: A Puzzle of Compliance
Many people are confused about the differences between GB 9685 and the GB 4806 series. In fact, they form a complete compliance puzzle. GB 4806.1 outlines general safety requirements, setting the basic safety baseline for food contact materials. GB 4806.6 to GB 4806.15 are specific standards for different materials, such as plastic, rubber, and paper. GB 9685 is the standard for the use of additives across all materials. Together, they form a complete compliance system. If you are not familiar with the general standards for materials, you can review our previously published content.Full Interpretation of the GB 4806 Series StandardsReading the two articles together will help you build a complete understanding of the national standards framework.
Summary: Compliance is the ticket to entry for food packaging
The GB 9685 standard for food contact materials is not a choice but a mandatory requirement for the food packaging industry. For manufacturers, it is the foundation of their quality management system; for buyers, it is the key criterion for selecting suppliers. When choosing a packaging supplier, GB 9685 compliance should be given equal importance to price, as food safety leaves no room for negotiation.
Huashu Packaging has been deeply involved in the flexible packaging industry for many years. All products are manufactured strictly in accordance with GB 9685 and GB 4806 series standards, equipped with a complete testing system and compliance records, and can provide complete compliance documents. If you are looking for a reliable food packaging bag supplier, welcome to contact us.Contact UsGet free sample and compliance consultation.
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