304 Stainless Steel Mesh China GB4806 Food Contact Materials Testing Process
Date：2025-09-27 09:32:49 Classification
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China has just completed the development of its new food contact regulatory system. The newly released standards series 4806.1-11 specify general and specific requirements for food contact materials and articles made of materials such as enamel, ceramics, glass, resins, plastics, paper and paperboard, metals, paints and coatings, and rubber. Based on the testing requirements for 304 stainless steel mesh as a food contact material in China's GB4806 series of standards, and in light of the latest regulations and industry practices, the testing process and key points are as follows:
I. Applicable Testing Standards
1. Core Standards
- GB4806.9-2023 "Food Contact Metal Materials and Articles" (mandatory implementation September 6, 2024)
- This replaces the previous version GB4806.9-2016 and adds differentiated migration requirements for alloying elements (such as chromium and nickel) and impurity elements (such as lead and arsenic).
- GB4806.1-2016 "General Safety Requirements"
Specifies that labels must indicate "food contact," material type (e.g., "304 stainless steel" or grade "06Cr19Ni10"), and operating conditions.
2. Supplementary Standards
- GB 31604 series: Migration test methods (e.g., simulated liquid immersion, temperature conditions).
- GB 9684-2011 "Stainless Steel Products": An older version of the hygiene standard, which some companies still refer to for physical and chemical indicators.
II. Testing Process and Steps
1. Preliminary Preparation
- Material Confirmation: 304 stainless steel requires material certification (grade 06Cr19Ni10) to ensure compliance with the composition requirements of GB20878-2007 (chromium 18-20%, nickel 8-11%).
- Sample Preparation: Cut stainless steel mesh samples according to actual usage, retaining any surface treatments (e.g., polishing, coating).
2. Submit Inspection Application
- Submit to a CMA-qualified laboratory:
- Application form (product name, intended use, and food contact type);
- Material composition report;
- Product design drawings and instructions for use.
3. Laboratory Testing Items
| Test Category | Specific Items
| Heavy Metal Migration | Dissolution of Lead (Pb), Cadmium (Cd), Arsenic (As), Chromium (Cr), Nickel (Ni), etc.
| Alloying Element Migration | Specific Migration Limits for Chromium and Nickel (New Standard Key Point)
| General Safety Items | - Total Migration (Simulated Fluids, such as 4% acetic acid and olive oil)
- Potassium Permanganate Consumption
- Sensory Testing (Odor, Discoloration)
4. Test Methods and Conditions
- Migration Test:
- Simulated Fluid Selection: 4% acetic acid, alcohol solution, or olive oil can be used depending on the type of food contact (acidic, aqueous, or oily).
- Temperature/Time: High-temperature use conditions are often simulated (e.g., 100°C for 2 hours).
- Chemical Analysis:
Heavy metals are detected using ICP-MS (Inductively Coupled Plasma Mass Spectrometry).
5. Report and Certification
- Declaration of Conformity (DoC):
After the laboratory issues the report, the company must prepare a DoC, which includes a statement of compliance with the standard, compliance with the limits, and conditions of use.
- Labeling:
Products must be labeled "For Food Contact Use," the material grade (e.g., "304 Stainless Steel"), and the temperature range.
III. Notes for Companies
1. Material Compliance
- 304 stainless steel itself meets food-grade requirements, but be wary of inferior substitutes (e.g., 201/202 stainless steel, which has high manganese content and is prone to heavy metal precipitation).
2. Transition Period to the New Standard
- GB4806.9-2023 will be mandatory starting in September 2024. Testing must confirm that the laboratory is operating in accordance with the new standard.
3. Cost and Turnaround Time
- The testing fee is approximately 2,000-5,000 RMB (depending on the number of items), and the turnaround time is typically 5-10 working days.
IV. Recommended Operations
1. Prioritize laboratories certified to GB4806.9-2023 (such as Dezewei Testing).
2. Production Control: Ensure that raw material suppliers provide an SGS report or material certification for 304 stainless steel.
3. Label Example:
> "Food Contact Stainless Steel Mesh, Material: 304 (06Cr19Ni10), Applicable Temperature: -20°C to 150°C."
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