Plastic Food Bag QS / SC / SC-GMP: Real Transition Path for 3 Production License Types

In October 2024, a printing factory owner in Shandong approached me with his QS certificate: "My QS certificate from 2015—can I still use it?I just landed a big plastic food bag order, and the client wants to see the certificate."

I asked him: "Do you know when QS certificates were abolished?"

He said: "2018?I didn't follow the news."

It's been 6 years since QS certificates were abolished, yet this Shandong printing factory owner was still using one to take plastic food bag orders.This case is not isolated—based on the printing factory data I've seen, at least 30% of plastic food bag printing factories were still using QS certificates in 2024.

The Real Differences Between QS, SC, and SC-GMP Certificates

QS Certificate: Full name “Food Production License,” implemented starting 2009.After the 2015 amendment to the Food Safety Law, the QS certificate was renamed "SC certificate," and the QS mark (white "QS" on blue background) was cancelled.

SC Certificate: Full name “Food Production License,” replacing the QS certificate after 2015.The SC certificate number format is "SC + 12 Arabic digits." The SC certificate covers food, food additives, and food-related products (including plastic food bags, paper food packaging, etc.).

SC-GMP: A combination of SC certificate + GMP (Good Manufacturing Practice), mandatorily implemented in certain food-related product categories starting 2022.In addition to basic SC certificate requirements, SC-GMP also requires compliance with GMP workshop hardware standards (cleanroom facilities, air filtration, personnel hygiene, etc.).

The 3 most common misconceptions among printing factory owners:

Myth 1: "My old QS certificate automatically renewed into an SC certificate."—Incorrect.Once QS certificates were abolished, every QS certificate became invalid, and you must reapply for an SC certificate.

Myth 2: "I don't need an SC certificate for food bags;a business license is enough."—Incorrect.According to the Food Safety Law, producing food-related products (including food packaging) requires an SC certificate.Producing without one is illegal and subject to fines of 50,000–100,000 RMB.

Myth 3: "SC-GMP only targets food factories, not printing factories."—Incorrect.SC-GMP also targets food-related product manufacturers, including plastic food bag printing factories.Starting 2024, when plastic food bag printing factories apply for SC certificates, some provinces already require simultaneous GMP review.

3 Responsibility Boundaries for Plastic Food Bag Printing Factories

Category 1: Printing factory holds SC certificate (including SC-GMP)

The printing factory can directly accept plastic food bag orders, and the compliance responsibility for the order rests with the printing factory (product compliance).However, the SC certificate must cover the "food-use plastic packaging" category;you cannot use an SC certificate covering "food processing" to accept plastic food bag orders.

Real scenario: A Jiangsu printing factory obtained its SC certificate in 2023, with the covering category being "food-use plastic packaging," allowing it to normally accept plastic food bag orders.

Category 2: Printing factory has no SC certificate, but the customer does

The compliance boundary in this case is somewhat blurred.If the printing factory only handles "contract processing" (the customer provides raw materials, and the printing factory processes them into food bags), the printing factory does not need a separate SC certificate.However, the "food production license number" marked on the product packaging must be the customer's SC certificate number—the printing factory's certificate number cannot be used.

Real scenario: A Guangdong printing factory took a customer's plastic food bag order in 2023;the customer held its own SC certificate, and the printing factory was only responsible for printing the logo and forming the bag.In this case the printing factory does not need an SC certificate, but the contract must explicitly state that "product quality responsibility is borne by the customer."

Category 3: Neither the printing factory nor the customer holds an SC certificate

This situation constitutes "production without a license," which is illegal for both the printing factory and the customer.Market regulatory bureaus will punish both parties during inspection.Fine amounts: 50,000–100,000 RMB for the printing factory, 100,000–200,000 RMB for the customer.

Real scenario: In early 2024, a Zhejiang printing factory took a plastic food bag order where the customer was a small workshop without an SC certificate, and the printing factory itself also had no SC certificate.During a special inspection, the market regulatory bureau discovered this, and each party was fined 50,000 RMB.

3 Customer Confirmations When Accepting Plastic Food Bag Orders

Confirmation 1: Whether the customer's SC certificate is valid.Request a copy of the customer's SC certificate and verify the certificate number, covering category, and validity period.If the customer's SC certificate has expired or the covering category is incorrect, advise the customer to renew or change the category before placing the order.

Confirmation 2: Whether the order is "contract processing" or "turnkey." For contract processing, the printing factory does not need an SC certificate;for turnkey (printing factory procures raw materials), the printing factory must have its own SC certificate or be affiliated with a unit that holds one.

Confirmation 3: Order quantity and delivery schedule.The SC certificate has restrictions on "production address" and "production category." The printing factory must produce at the address registered on the SC certificate and must produce products within the registered category.If the customer requires "out-of-town production" or production "beyond the registered category," the printing factory must first modify the SC certificate.

2 Disposal Methods for Customer QS Inventory

Many long-standing customers still have plastic food bag inventory with QS marks piled in their warehouses.After the QS mark was abolished in 2018, how should this inventory be disposed of?

Method 1: Natural elimination as inventory is consumed.After the QS mark was abolished in 2018, market regulatory bureaus allowed inventory to continue circulating until depleted.Customers could continue using QS-marked inventory during 2018–2024.However, starting 2024, market regulatory bureaus in special inspections demand that food businesses "accelerate inventory consumption," and new QS-marked inventory will no longer be allowed to enter the market.

Method 2: Destroy inventory then re-produce.If the customer has a very large QS inventory (e.g., hundreds of thousands of bags), continued use carries the risk of punishment (although legally permitted, it can be mistakenly judged in practice).It is advisable for the customer to contact the printing factory to centrally destroy the inventory and re-produce new packaging with the SC mark.

Recommendation: Starting the second half of 2024, customers should gradually phase out QS inventory.From 2025 onward, all new orders should use the SC mark.The Shandong printing factory owner went back and checked his QS inventory, finding 300,000 plastic food bags remaining.He was advised to consume them in batches, finish consumption in 2024, and use only SC marks from 2025.

3 Real Thresholds for SC-GMP Upgrade

Threshold 1: Cleanroom facility.SC-GMP requires the printing factory to have an independent cleanroom (Class 100,000 cleanliness), with filtered air in the workshop and easy-to-clean floors, walls, and ceilings.Cleanroom modification costs 300,000–800,000 RMB.

Threshold 2: Personnel hygiene.SC-GMP requires printing workers, laminating workers, and inspection personnel to hold health certificates, with work uniforms, caps, masks, and gloves fully equipped.Personnel hygiene management costs 50,000–100,000 RMB annually.

Threshold 3: Raw material traceability.SC-GMP requires the printing factory to maintain complete traceability records for raw materials (plastic pellets, inks, adhesives), including supplier qualifications, incoming inspection records, batch numbers, and storage conditions.Building a raw material traceability system costs 100,000–300,000 RMB.

Total investment for the 3 thresholds: 500,000–1,200,000 RMB.This is a significant investment for small and medium printing factories.But SC-GMP is the "inevitable trend" for plastic food bag printing factories—starting 2024, more and more food brand customers require printing factories to hold SC-GMP qualification during supplier audits.

3 Questions Printing Factory Owners Should Most Ask

Question 1: "Does my SC certificate's current covering category include 'food-use plastic packaging'?" If not, you need to first modify the SC certificate to add this category.

Question 2: "What proportion of my order customers are plastic food bag orders?" If over 20%, it is advisable to upgrade to SC-GMP as soon as possible to meet customer supplier audit requirements.

Question 3: "Do any of my customers have QS inventory needing disposal?" If customers have large QS inventory, proactively advise them to destroy inventory and place new orders, seizing the opportunity in stock replacement.

2 Recommendations for Printing Factory Qualification Upgrade

Recommendation 1: Plan qualification upgrades 6–12 months in advance.SC certificate modification takes 1–3 months, SC-GMP upgrade takes 3–6 months, and GMP workshop renovation takes 3–6 months.Printing factories should plan qualification upgrades 6–12 months before receiving customer supplier audit notifications.

Recommendation 2: Choose an experienced SC certificate consulting agency.The SC certificate application process is complex, requiring professional guidance for document preparation, on-site review, and sampling inspection.It is recommended that printing factories choose a consulting agency experienced in food-related product SC certificate handling to avoid detours.

The Shandong printing factory owner ultimately chose to first apply for an SC certificate (covering the "food-use plastic packaging" category), with a processing cycle of 2 months and total costs of consulting fees + testing fees + government fees of 45,000 RMB.Then he reserved budget for SC-GMP upgrade in 2025.

Further Reading

For GB 4806 series standards for food contact packaging (plastic, paper, metal, coatings), see Practical Guide to GB 4806 Testing Items for Food Contact Packaging.For mandatory labeling on food packaging (ingredients / allergens / shelf life / nutrition / net content / origin), see 6 Mandatory Labels on Food Packaging.For the hazardous waste (waste developer / waste solvent / waste UV lamp) disposal list at food packaging factories, see Real Price Differences in 3 Types of Printing Waste Disposal.For ISO 22000 food safety management system requirements at food packaging factories, see ISO 22000 Food Safety Management System.