Food Packaging 5 Core Standards: GB 4806.1/7/8/9/11—3 Numbers Print Shops Must Confirm Before Taking Orders

In April 2026, a customer producing frozen ready-to-eat crawfish approached us. Their exact words were:

"Hey, our product will be sold through Hema and Dingdong Maicai. I've already had the design company prepare the packaging design, with green lettering on a white background—it looks clean and fresh. Just have your printing factory follow the design; you’re the professionals when it comes to production techniques."

It sounds perfectly normal—the customer provides the artwork, and the printing factory follows it. But once we opened the files, we found that the inner bag used ordinary PE lamination, while the outer box used coated paper with gloss film. The customer sells -18℃ frozen crayfish, yet the inner bag, which comes into direct contact with food, is not made of food-grade PE. This is a classic case of the customer lacking the necessary expertise, the printing factory simply following instructions, and problems arising in the end.

When a printing plant takes on a food packaging order, the real difficulty is not printing but the fact that 5 GB 4806 series standards take effect simultaneously: GB 4806.1 General Principles, GB 4806.7 Plastics, GB 4806.8 Paper, GB 4806.9 Metals, and GB 4806.11 Coatings—if any material is assigned to the wrong standard, the product will be taken off the shelf following an inspection by the market supervision authority, and the printing plant will also face liability for penalties.

Category 1: GB 4806.1 General Principles—The 3 “Basic Requirements” Printers Most Often Get Wrong

GB 4806.1 serves as the “general principles” of the entire GB 4806 series, and all food-contact materials must comply with it first. Printing plants often stumble over GB 4806.1 because they fail to properly understand three basic requirements:

Case 1. The migration test report did not correspond to a specific formulation. A printing plant produced milk tea cups for a brand, which provided a 2021 GB 4806.7 report stating, “The PE coating we use has passed the migration test.” However, the new national standard in 2026 requires each formulation to be tested separately, and a group-wide generic report cannot be used. During a spot inspection in 2026, the market supervision authority directly determined that the migration levels exceeded the limits, and the printing plant was consequently fined RMB 30,000.

Case 2. “Indirect Contact” Label Printed Incorrectly. A food factory producing biscuit outer boxes mislabeled GB 4806.1 “indirect contact with food” as “direct contact with food” in the design draft. Upon inspection by the market regulatory authority, the inner bags were not food-grade PE, yet the packaging stated “direct contact,” and the entire batch was rejected and returned.

Case 3. Ink not labeled “food grade”. A printing plant used ordinary offset ink (not food grade) for the color printing of potato chip bags. After the outer surface of the bag was printed, it came into direct contact with aluminum foil. GB 4806.1 explicitly requires that inks comply with the list in Appendix A of GB 4806.7; inks not included in the list are not permitted for use in food packaging.

Category 2: GB 4806.7 Plastics — Misapplications of the 4 Most Commonly Used Materials in Printing Plants

GB 4806.7 is the general standard for food-contact plastics. Printing plants most often run into compliance issues under this standard, mainly because the corresponding requirements for the 4 categories of materials are misapplied:

1. Mixing PE extrusion coating with PE blown film. Although both are PE, extrusion coating is used for the inner walls of paper cups (in conjunction with GB 4806.8 paper substrates), while blown film is used for plastic bags, and their migration test conditions differ. A printing company used a PE blown film test report for PE extrusion-coated cups, and the market supervision authority determined during random testing that the migration exceeded the permissible limit.

2. PET Report Used for PP Meal Containers. PP and PET are two different plastics, and GB 4806.7 clearly requires testing by material. A printing factory applied the migration report for PET bottle preforms to PP meal containers, and the report was deemed invalid by a professional testing institution.

3. PLA corn starch meal boxes were not tested separately. PLA is not included in the traditional list in GB 4806.7, so it must follow the “new material” pathway and undergo separate testing for migration and compostable degradation. When a printing plant accepted an export order and used domestically produced PLA meal boxes, the brand owner requested an EN 13432 report for EU listing, only then did the printing plant realize that no such report was available.

4. PVC packaging was not tested for phthalates. GB 4806.7 specifies clear limits for phthalates such as DEHP in PVC. A printing company produced PVC candy packaging without testing for these substances, and the products were recalled after being listed on the EU market by a European customer.

Category 3: GB 4806.8 Paper Materials — The 3 Items to Confirm First Before the Printing Factory Submits Samples for Testing

GB 4806.8 applies to paper, paperboard, and pulp molding intended for direct contact with food. The three types of issues most commonly encountered by printing plants in this category are:

1. Excessive fluorescent whitening agents. GB 4806.8 expressly prohibits the use of fluorescent whitening agents in food-contact paper. A printing plant used coated paper containing fluorescent whitening agents for a white cake box. After the customer put the boxes on the market, they were selected for random inspection by professional counterfeiters, and the entire batch was taken off the shelves.

2. Recycled paper is not labeled “non-food grade.” Recycled paper pulp molded trays (such as egg trays) that directly contact cooked food must be clearly labeled “non-food grade” or fitted with food-grade inner bags. A printing company produced takeaway meal boxes using recycled paper molded trays to package cooked food, and the market supervision authority determined during random inspection that this was a violation.

3. The coating material of the paper-based coating is not specified. If the coating on a paper cup is PE/PLA/PBS, it must be clearly identified. A printing factory produced coffee cups using PE coatings, but the labels stated PLA. After the brand launched the products, they were reported by professional counterfeiters for “false advertising.”

Category 4: GB 4806.9 Metals — The 3 Most Common Pitfalls in Canning Plants

GB 4806.9 applies to food-contact metals. Few printing companies directly produce metal packaging (mainly canneries), but caution is needed when a printing company handles "metal + plastic composite" packaging (such as infant formula cans):

1. Non-compliant coating on the inner walls of tinplate cans. A printing factory for milk powder cans used ordinary epoxy phenolic coating that failed the GB 4806.11 coating test. After the products were put on the market, a spot check found that the free phenol content exceeded the specified limit.

2. Industrial aluminum foil for foil bags. A printing plant used industrial aluminum foil (not food grade) for individual biscuit packaging, resulting in heavy metal migration levels 3 times the permissible limit.

3. Incorrect 304 / 316 labeling on the interior wall of the stainless steel vacuum flask. A printing company accepted an order for vacuum flasks. The customer’s design specified “304 stainless steel,” but the printing company actually used 201 stainless steel (industrial grade). The market supervision authority’s spot inspection found that inferior material had been passed off as compliant material.

Category Five: GB 4806.11 Coatings—only needed by printing plants for canned food and metal containers

GB 4806.11 applies to food-contact coatings and coatings, primarily for the inner walls of cans, beverage cans, and metal containers. When printing plants accept orders of this type, they most commonly run into 3 issues:

1. Excessive free phenol in epoxy phenolic coatings. Free phenol is carcinogenic, with a limit of ≤ 0.1 mg/kg under GB 4806.11. A printing factory used domestically produced epoxy coating for the inner walls of tomato sauce cans. When exporting to the EU, EN 13130 testing determined that free phenol exceeded the limit.

2. PVDF coatings are not resistant to high temperatures. PVDF (polyvinylidene fluoride) is a high-end, food-grade coating material that withstands temperatures above 150℃. A printing plant used ordinary PVDF to coat a baking mold, and the coating developed bubbles after baking at 180℃ for 30 minutes.

3. Incorrect migration test conditions for water-based coatings. The migration test conditions for water-based coatings and solvent-based coatings are different: the former uses a 10% aqueous ethanol solution, while the latter uses a vegetable oil simulant. A printing plant mixed up the test conditions, and the test report was ruled invalid.

Further reading

How to Read the 9 Standards in the GB 31604 Series for Food Contact Packaging: Migration, Additives, and General Requirements—3 Types of Testing Thresholds—and Where Printing Plants Most Commonly Fail: Missing General Requirements

Metal Packaging vs. Plastic Packaging: A Food Safety Comparison of 3 Types—Cans / Aluminum-Coated Packaging / Composite Bags—The Issue Printing Plants Most Often Face: Free Phenol in Aluminum-Coating Adhesive

Six Types of Mandatory Food Packaging Labels: Ingredients / Allergens / Shelf Life / Nutrition Facts / Net Content / Place of Origin—The 3 Most Common Pitfalls for Printing Companies

Biodegradable vs. Compostable vs. Recyclable: Rethinking the Confused Use of 3 Types of Labels and the Compliance Boundaries for Brands Entering European and American Markets

Four Certification Standards for Compostable Packaging: ASTM D6400 / EN 13432 / GB/T 19277 / HJ/T 209—Three Costs Printing Plants Should Calculate Before Sending Samples for Testing