ARTICLE
2 March 2020

China's CFSA Notice Solicits Comments On 10 New Food-Contact Products

SJ
Steptoe LLP

Contributor

In more than 100 years of practice, Steptoe has earned an international reputation for vigorous representation of clients before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. Steptoe has more than 500 lawyers and professional staff across the US, Europe and Asia.
On February 18, 2020, China's National Center for Food Safety Risk Assessment (CFSA) published a notice soliciting public comments on 10...
China Food, Drugs, Healthcare, Life Sciences

On February 18, 2020, China's National Center for Food Safety Risk Assessment (CFSA) published a notice soliciting public comments on 10 new food-related products, which have passed the technical review of the expert review committee according to China's Regulations on Administrative Licensing of New Varieties of Food-related Products and Regulations on Application and Acceptance of New Varieties of Food-related Products. The notice (in Chinese) can be found here.

There are three annexes linked to the notice: Annex 1 lists the additives for which expanded clearances (i.e., positive listings) have been requested; these include calcium stearate (CAS No. 1592-23-0) and 2,5-funrandione, dihydro-, mono-C12-20-alkenyl derivs. (CAS No. 68784-12-3). Annex 2 lists additives that are the subject of requests for new clearances, including microfibrillated cellulose pulp (CAS No. 65996-61-4) and 2-butenedioic acid (2E)-, dibutyl ester, homopolymer. Finally, Annex 3 lists draft resin clearances. These include fatty acid, C18-unsaturated, dimers, polymers with caprolactam and hexamethyldiamine (CAS No. 2068097-08-3); 2-propenoic acid, 2-methyl-, polymer with N-(butoxymethyl)-2-propenamide, ethylbenzene and ethyl -2propenoate (CAS No. 26589-46-8); styrene block polymers with 2-methyl-1,3-butadiene and 1,3-butadiene, hydrogenated (CAS No. 132778-07-5); phenol, 4,4’-(1-methylethylidene)bis-, polymer with (chloromethyl)oxirane, benzoate (CAS No. 52907-82-1); polymer of 1, 4-bis(hydroxymethyl)cyclohexane, 2-methylpropane-1,3-diol, tricyclo(5.2.1.0)decan-4,8-dimehtanol, benzene-1,4-dicarboxylic acid, benzene-1,3-dicarboxylic acid, cis-butenedioic acid, 5-isocyanato-1-isocyanatomethyl-1, 3,1-trimethylcyclohexane; and polymer of butanediol-1,4, ethylene glycol, propylene glycol-1,2, trimethylolpropane, dimethyl terephthalate, isophthalic acid, and sebacic acid. 

Following this announcement for public comment, the next steps to gaining access to the market in China pursuant to the above-listed clearances will be intergovernmental consultations, the Ministry of Health's (MOH) internal routine, approval of the listings, and the final public announcement for final approval. The deadline for comments is March 11, 2020.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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