Here's a scenario that plays out constantly at Chinese customs: a shipment of food packaging is held because one additive in the plastic isn't on an approved list. The product is perfectly legal in the EU. It doesn't matter. In China, one standard decides what you can put in anything that touches food — and if you're not on it, you don't ship.
That standard is GB 9685, the National Food Safety Standard for additives in food-contact materials. It's mandatory. It lists roughly 1,294 approved additives and, for each one, exactly where and how much you may use it. Miss the list, or exceed a limit, and your material is non-compliant — no matter how safe it is anywhere else in the world.
If you're exporting food packaging to China and haven't mapped your formulation against GB 9685, stop and read this first. A single unlisted additive can strand a container at the border.
What GB 9685 Actually Controls
GB 9685 covers additives across every major category of food-contact material. For each approved substance it defines up to four limits:
| Limit | What it means |
|---|---|
| Maximum use level (QM) | How much of the additive may go into the material during production |
| Specific migration limit (SML) | How much may migrate from the material into the food |
| Maximum residual quantity (QMA) | How much may remain in the finished article |
| Total specific migration limit (SML(T)) | Combined migration cap when several listed substances migrate as the same chemical |
The permitted-substance tables (Annex A) are organised by material type:
- Plastics
- Coatings and printing inks
- Rubber and silicone rubber
- Adhesives
- Paper and board
- Other food-contact materials
Each entry carries an FCA number (the standard's own additive ID), a CAS number, its permitted scope of use, and its limits. Annexes B and C hold the grouped migration totals and the metal-element restrictions.
The 2016 Edition and the 2025 Amendment
The current base text is GB 9685-2016, which replaced the 2008 edition. It has since been updated by Amendment No.1 (2025XG1), which revises and extends the list of permitted additives. When people ask for "GB 9685-2025", they usually mean the 2016 standard as amended — the consolidated text most exporters need to work from.
This matters in practice: a formulation that was compliant under an older list may need rechecking against the amended entries, and new additives that were previously unlisted may now have an approved pathway.
Who Needs to Comply
GB 9685 applies to a long chain of businesses, not just the final packaging maker:
- Converters and packaging manufacturers selling into China
- Brand owners whose products ship in food-contact packaging
- Importers responsible for placing compliant goods on the market
- Additive and masterbatch suppliers whose ingredients must be on the list
- Food-contact testing laboratories running migration tests
How GB 9685 Compares to the EU
This is where most exporters get burned. The EU controls food-contact plastics through Regulation (EU) No 10/2011 and its Union list — and it's natural to assume that a product cleared for Europe is a safe bet for China too. It isn't. The two lists are not interchangeable: a substance approved in the EU can be completely absent from GB 9685, and where both list it, the limits often differ. "It passed in Europe" is not a compliance argument in Shanghai. Check each market against its own list, every time.
Common Mistakes That Get Shipments Blocked
Most GB 9685 failures are not exotic. They repeat, again and again:
- A colour masterbatch with an unlisted pigment. The plastic itself is fine, but the colourant added at the last step contains a substance not in Annex A. The whole product fails.
- A printing ink or adhesive that no one checked. Teams often test the plastic and forget that the ink on the label or the glue on the seal is also a food-contact material under GB 9685.
- An additive listed for plastics, used in rubber. Being on the list is not enough — a substance is only approved for the material types and uses written next to it. The same additive can be allowed in one material and banned in another.
- Trusting a supplier's word. "It's food-grade" is not the same as "it meets GB 9685." Without the FCA/CAS numbers and limits in writing, you have nothing to show an inspector.
Who Is Responsible
A key point that surprises many companies: the importer or the business placing the product on the Chinese market is responsible, even if the packaging was made abroad. You cannot fully push the risk onto an overseas supplier. If the goods reach China and fail, it is your shipment that is held, and your customer who is left waiting.
Practical Steps for Compliance
Work through these in order before you ship:
- List every substance in the finished article. Not just the base plastic — include colourants, inks, coatings, adhesives, and any processing aid that could remain in the product.
- Match each one to its entry in Annex A. Find its FCA number and CAS number in the tables for your specific material type (plastic, coating, rubber, etc.).
- Check the scope and the limits. Confirm the substance is approved for your use, and that you stay within its use level and migration limit — including any SML(T) group total when several substances migrate as the same chemical.
- Use the amended list, not the old one. Check against Amendment No.1 (2025XG1), not only the 2016 base text — the approved entries have changed.
- Get migration testing done. Have an accredited food-contact laboratory run the tests and give you a report you can hand to customs or a customer.
- Keep the paperwork. Store the substance list, approvals, and test report together, so you can prove compliance the day someone asks.
You can't check your formulation against a list you can't read. The official text is Chinese-only — so if your compliance or lab team needs to work through Annex A line by line, get it in a language they actually use.
Get the full English PDF of GB 9685 (2016 + Amendment No.1) now — instant download, delivered in seconds, invoice included. Not sure which edition you need? Ask us and we'll point you to the right one.