China's GB 4806 Series: Food Contact Metal Standards Explained

📅 Aug 28, 2026 👁 views

China's GB 4806 series is the domestic food contact framework, and it matters to an exporter for two reasons: it governs products sold in China, and it is a useful reference framework because its requirements for metals are explicit and testable. Many factories already hold GB test reports, and those reports can support a compliance position when used for what they actually cover.

This article explains the GB 4806 series as it applies to metal cutlery.

The structure of the series

Part	Scope	Relevance to cutlery
GB 4806.1	General safety requirements for food contact materials and articles	The overarching principles, including the requirement for a compliance statement
GB 4806.3	Enamelware	Relevant if any enamel decorative element is used
GB 4806.4	Ceramic articles	Not directly relevant, unless ceramic components are used
GB 4806.7	Plastics	Applies to plastic handles and to any plastic in the food contact zone
GB 4806.9	Metals and alloys	The key part for a steel blade, bolster and any metal handle element
GB 4806.10	Paints and coatings	Applies to any coated surface
GB 4806.11	Rubber	Applies to any rubber grip element
GB 4806.12	Other materials, including wood, paper and bamboo	Applies to wooden handles and to some packaging materials
GB 31604 series	Test methods	The methods used to demonstrate compliance

GB 4806.9 for metals and alloys

Requirement	What it covers	Practical note
Material requirements	Permitted alloy composition for food contact metals	The grade must be within the permitted composition; some low-cost grades with high impurity levels are not
Migration limits	Limits for specific metals migrating into a food simulant	Explicit numeric limits, which makes the standard testable rather than judgement-based
Test conditions	Simulant, temperature and exposure time per the intended use	Defined in the standards rather than left to the laboratory
Exclusions	Some metallic components are excluded from the migration requirement in specified circumstances, for example certain components not in direct contact	Position in the contact zone determines applicability
Compliance statement	The product must be accompanied by information identifying the manufacturer, the material and the compliance basis	Required by GB 4806.1

The migration limits in GB 4806.9 are explicit and enforced, which makes the standard practically useful. A factory with a current GB 4806.9 report for a specific grade has demonstrated something concrete about that grade.

Other parts that apply to a kitchen knife

Part	Applies when	What it requires
GB 4806.7, plastics	Plastic or polymer handle, or a plastic element in the contact zone	Permitted resin and additive list, overall and specific migration limits, sensory requirements
GB 4806.10, coatings	Any coating on the blade or handle, including decorative	Coating substance restrictions and migration requirements
GB 4806.11, rubber	Rubber or elastomer grip components	Formulation and migration requirements
GB 4806.12, others	Wooden handles, and materials not covered elsewhere	Requirements for the specific material, including treatment and additives
GB 4806.1, general	Always	General safety, sourcing of material, and the compliance information obligation

Using a GB report for export markets

Question	Answer
Does a GB report satisfy an EU buyer?	No. It is evidence that the material passed a defined test, but the EU requires its own framework compliance and declaration, and the test conditions and limits differ
Is a GB report useful evidence in the EU?	It is supportive evidence about the material, not a substitute for EU testing or a declaration
Does a GB report satisfy a US importer?	No. The US framework is different. It may be referenced as supporting material evidence
Is a GB report useful for a Chinese domestic claim?	Yes, it is the relevant scheme, together with the compliance statement
Can it reduce testing cost elsewhere?	Sometimes it can inform a risk assessment and reduce the scope of a required test, but do not present it as equivalence

The common mistake is using a GB test report in a European sales conversation as if it were an LFGB or a declaration of compliance. It is not, and presenting it as such is a documentation error that a competent buyer will catch. See EU compliance and LFGB testing.

Practical standard selection

Selling where	Primary requirement	Secondary, useful evidence
China domestic	GB 4806 series, with a compliance statement	Factory internal test data and process control records
European Union	Framework regulation compliance, declaration of compliance, EU responsible operator	LFGB or equivalent test report as supporting evidence
Germany specifically	Framework regulation plus LFGB expectations from retail	GB 4806.9 data as background
United States	No adulteration; supplier declarations for polymers and coatings; Prop 65 assessment	Any migration testing as supporting evidence
Japan	Food sanitation law requirements and Japanese labelling	Test data to the relevant Japanese specification
Gulf markets	Gulf standards and Saudi or Gulf conformity requirements	Testing to the applicable Gulf standard

Testing scope for a metal knife under GB 4806

Component	Applicable part	Test
Blade and bolster, in contact zone	GB 4806.9	Migration of regulated metals into the specified simulant under the specified conditions
Plastic or polymer handle	GB 4806.7	Overall migration, specific migration, sensory
Coated surface	GB 4806.10	Coating specific requirements and migration
Rubber grip elements	GB 4806.11	Formulation and migration requirements
Wooden handle	GB 4806.12	Material specific requirements, including any treatment
Product information	GB 4806.1	A compliance statement with the required information

Verifying a factory's GB report

Which part of the GB 4806 series does the report reference?
Which material is named, and with what composition?
What simulant and exposure conditions were used?
Which elements were tested and what limits were applied?
Is the report current, and has the material or supplier changed since?
Does the report cover the contact zone components, or only the blade?
Is there a compliance statement as GB 4806.1 requires?
Will the factory permit the report to be referenced in your own documentation for a different market, clearly identified as a GB report and not as the destination scheme?

Question eight matters for honesty. A brand can reference supporting evidence, but it must not present a GB report as an EU or US compliance document. Misrepresenting the scheme is a fast way to lose a buyer's confidence when it is discovered. See auditing customer-facing facts.

Why the Chinese framework is worth knowing even if you do not sell in China

It defines explicit limits for metal migration, which is a useful reference when evaluating a material.
Many factories hold GB reports, which are a free source of material information.
It demonstrates what a fully specified metal food contact standard looks like, which makes the EU position — a framework plus national measures plus a declaration — easier to understand.
If your product is manufactured in China, domestic rules may apply to the factory's own compliance obligations independently of your destination market.