Overview
GB 4806.9-2023 is China’s National Food Safety Standard for food-contact metal materials and articles. It was issued on 6 September 2023 and took effect on 6 September 2024, replacing GB 4806.9-2016. GB 4806.9 sets specific migration limits: the maximum amount of each element that may release from the finished article into food or a food simulant under the standard’s migration test. The 2023 revision lowered the impurity-element migration limits and, for the first time, added migration limits for alloying elements.
The distinction between migration and composition is load-bearing for any use of this standard. A composition limit expressed as percent by weight, such as the Korean MFDS 0.10 percent lead cap on food-contact metal or the equivalent Japanese alloy-content rule, governs the metallurgy of the substrate and says nothing about how much metal reaches food. A migration or release limit expressed in mg/kg of food or simulant governs the contamination outcome. GB 4806.9-2023 is a migration instrument, and its values sit three to five orders of magnitude below any percent-by-weight composition cap.
Exact limits and units
Migration is measured into the food simulant selected under GB 31604.1, with the metal-migration test method given by GB 31604.49-2016 Part Two. Values are the maximum permitted migration into food or simulant.
Impurity elements (GB 4806.9-2023 Table 3)
| Element | Limit (mg/kg) | Limit (µg/kg) | Notes |
|---|---|---|---|
| Arsenic (As) | 0.002 | 2 | Uncoated iron frying pan: 0.018 mg/kg (18 µg/kg) |
| Cadmium (Cd) | 0.002 | 2 | |
| Lead (Pb) | 0.01 | 10 | |
| Antimony (Sb) | 0.04 | 40 |
Alloying elements (GB 4806.9-2023 Table 4)
| Element | Limit (mg/kg) | Limit (µg/kg) | Notes |
|---|---|---|---|
| Aluminium (Al) | 1 | 1000 | Uncoated aluminium and aluminium-alloy articles: 5 mg/kg (5000 µg/kg) |
| Chromium (Cr, total) | 0.25 | 250 | Total chromium migration, not hexavalent-specific |
| Cobalt (Co) | 0.02 | 20 | |
| Copper (Cu) | 4 | 4000 | |
| Manganese (Mn) | 2.0 | 2000 | |
| Molybdenum (Mo) | 0.12 | 120 | |
| Nickel (Ni) | 0.14 | 140 | |
| Tin (Sn) | 100 | 100000 | Not applicable to tinned thin-sheet containers, whose tin migration follows GB 2762 |
| Zinc (Zn) | 5 | 5000 |
Composition prohibitions
Separate from the migration limits, GB 4806.9-2023 restricts substrate metallurgy: lead, cadmium, arsenic, mercury, antimony, beryllium and lithium may not be used as intentional alloying elements in a metal substrate or metal coating. Mercury therefore carries no migration limit in this standard because it is prohibited as an alloying element rather than capped on release.
How tested
The migration test is performed under GB 31604.1 and GB 5009.156, with element-specific determination under GB 31604.49-2016 Part Two, and analytical methods still under development for several alloying elements at the time of the notified draft. Reusable articles undergo three successive migration tests; for stainless steel, compliance is judged on the third test unless the first result is within the limit and further increase can be excluded. Which alloying elements must be measured is determined by the material’s composition, for example manganese, chromium, nickel and molybdenum for a 32Cr13Mo martensitic stainless steel, and by the coating composition for a plated surface.
Enforcement posture
GB 4806.9-2023 is a statutory Chinese national food safety standard. Food-contact metal materials and articles placed on the Chinese market must comply with the applicable migration and composition requirements. It supersedes GB 4806.9-2016, whose impurity-element migration limits, for example lead at 0.05 mg/kg, were five to twenty times higher than the 2023 values.
How it compares
GB 4806.9-2023 is closely aligned with the Council of Europe technical guide under Resolution CM/Res(2013)9, which sets specific release limits in mg/kg food. For the shared elements the two instruments are near-identical: chromium 0.250, nickel 0.14, tin 100 and arsenic 0.002 mg/kg match, while GB is tighter on cadmium (0.002 versus 0.005 mg/kg) and the Council of Europe guide adds a mercury release limit (0.003 mg/kg) that GB handles through its alloying-element prohibition instead. Both are migration instruments and both sit far below the percent-by-weight composition caps of the Korean MFDS and Japanese food-contact metal rules, which regulate substrate content rather than release. The EU governs metal migration from plastic food-contact materials through Regulation 10/2011 Annex II; GB 4806.9 is the metal-article counterpart China applies directly to the finished metal surface.
Sources
- USDA Foreign Agricultural Service GAIN report, “China Notifies Draft National Food Safety Standard - Metal Materials and Products for Food Contact” (notified 2020-10-07; the notified draft became GB 4806.9-2023), Tables 3 and 4. Local copy:
raw/regulatory/cn/china-metal-fcm-gain-2020.pdf. - GB 4806.9-2023 final-standard confirmation of the alloying-element migration values (chromium 0.25, nickel 0.14 mg/kg) and the 2024-09-06 effective date replacing GB 4806.9-2016, via CIRS Group and C&K Testing standard summaries. Local copy of the standard front matter:
raw/regulatory/cn/gb4806.9-2023-cirs.pdf.
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