GB 4806.14-2023 Food-Contact Inks: Three Practical Boundaries—Direct Contact, Indirect Contact, and Migration Testing | What a Printer Should Check First When Asked Whether Ink Can Be Used on a Food Box
💡 💡 At a Glance
GB 4806.14-2023 establishes three practical boundaries for food-contact inks. First, direct versus indirect contact is determined by printing position, not ink grade. Direct-contact inks must use basic raw materials and additives approved under GB 2760 and related announcements, while indirect-contact inks must use colorants meeting GB 9685 purity requirements and must not contain colorants based on lead, mercury, cadmium, chromium, arsenic, selenium, or their compounds. Clause 6.2.2 also requires labeling or accompanying documents to state the ink category, recommended substrates, printing process, and special use requirements. Clause 4.3 requires printers to minimize ink use while achieving the intended effect and to control risks through measures such as effective barrier layers. Second, the numerical requirements for ink itself and printed ink layers are separate. Clause 5.3.1.1 covers heavy-metal residues in the ink, calculated on dry weight: Pb ≤10, Hg ≤10, Cd ≤5, Cr ≤25, and As ≤5 mg/kg. Clause 5.3.1.2 covers migration from the printed ink layer: total migration ≤10 mg/dm², or ≤60 mg/kg for products specifically intended for infants and young children; potassium permanganate consumption ≤10 mg/kg; and heavy metals expressed as Pb ≤1 mg/kg. Testing is conducted under GB 31604.1 and GB 5009.156. Third, aromatic primary amines must not be detected at a detection limit of 0.01 mg/kg. This requirement has a narrow trigger: it applies to printed ink layers containing aromatic isocyanates, azo colorants, or other substances capable of producing these amines, and testing must be performed on the finished product after drying and curing. For a food-box order, printers should first check three matters: the position of the printed surface, the two sets of compliance documents, and whether the ink triggers aromatic-primary-amine testing.
In October 2026, a client from a meal-replacement brand sent us the print file for a paper cup with a polite note: “We use food-grade ink, so please rest assured.”
We replied: “When you say food-grade, which level do you mean?”
The client answered: “You know, the kind of ink used for food packaging. The supplier’s instructions say it complies with food-contact standards.”
We asked another question: “Is the printed surface of this cup on the inside or the outside?”
The client paused: “…The outside. The inside is white.”
At that point, the issue became clear. If the client had provided the standard number from the outset, we could have replied within ten minutes. The problem was that “food-grade ink” has become almost meaningless in China’s packaging industry. Whether the supplier’s documentation says so is one matter; where the ink is printed is another.
GB 4806.14-2023, National Food Safety Standard—Inks for Food Contact Materials and Articles, was published in September 2023 and took effect in September 2024. It is China’s first dedicated standard for food-contact inks. It covers the ink itself, the printed ink layer it forms, and compatible varnishes. This article explains three practical boundaries and identifies what a printing company should check first when accepting an order for a food box.
First Boundary: Direct and Indirect Contact Are Defined by Printing Position, Not Ink Grade
The standard divides food-contact inks into two categories: inks for direct contact with food, which are printed on the food-contact surface of a food-contact material or article and are intended to come into direct contact with food; and inks for indirect contact with food, which are printed on a non-food-contact surface, are not intended to come into direct contact with food, but whose constituents may migrate into food.
These categories are determined by printing position, not by ink quality. The same can of ink printed on the outside of a cup is for indirect contact, while the same ink printed on the inside of a container holding yogurt is for direct contact. The applicable raw-material requirements are entirely different.
For printers, the practical significance is as follows: For direct-contact inks, basic raw materials and additives must be substances approved for use under GB 2760 and related announcements. For indirect-contact inks, colorants must meet the purity requirements of GB 9685, and colorants based on lead, mercury, cadmium, chromium, arsenic, selenium, or their compounds must not be used.
The client asked: “Can we use an indirect-contact ink then? It does not touch the beverage anyway.”
We replied: “Yes. But you need to confirm two things: whether the supplier has classified it as an indirect-contact ink, and which substrates the ink is permitted to print on.”
There is a practical trap here: Clause 6.2.2 requires ink products to identify their category—ink for direct contact with food or ink for indirect contact with food—on the label or accompanying documents, and to state the recommended printing substrates, printing processes, such as curing time, and any special use requirements. In other words, whether a can of ink may be used on laminated paperboard is not something a printer should determine on-site. It is a matter that the ink supplier must commit to in the accompanying documentation. If the supplier has not stated it, the printer should not infer it.
Another provision has a direct impact on costs. Clause 4.3 states clearly that printing enterprises for food-contact materials and articles should control safety risks arising from ink through measures such as packaging design, raw-material formulation and selection, printing-process control, product-information communication, and/or the addition of effective barrier layers. While achieving the intended printing effect, ink usage should be minimized as far as possible.
This requirement can be translated into concrete production actions. If a client insists on a solid dark background but the structure already permits an effective barrier layer—for example, an aluminum-plastic laminate lining—the ink-related risk of the package can be reduced. A printer can make this judgment when accepting the order, but only if the printer asks proactively.
Second Boundary: Two Sets of Numbers Cannot Substitute for Each Other—Heavy-Metal Residues in the Ink Are Not the Same as Migration from the Printed Ink Layer
This is where printers most often make mistakes in document review. The physical and chemical requirements of GB 4806.14 are divided into two separate sets.
The first set assesses the ink itself: heavy-metal residues, calculated on the dry weight of the ink, must not exceed Pb 10 mg/kg, Hg 10 mg/kg, Cd 5 mg/kg, Cr 25 mg/kg, or As 5 mg/kg.
The second set assesses the finished product after printing, meaning the printed ink layer: total migration must not exceed 10 mg/dm², with a limit of no more than 60 mg/kg for food-contact materials and articles specifically intended for infants and young children; potassium permanganate consumption must not exceed 10 mg/kg; heavy metals, expressed as Pb, must not exceed 1 mg/kg; and aromatic primary amine migration must not be detected, with a detection limit of 0.01 mg/kg. Migration testing must be conducted in accordance with GB 31604.1 and GB 5009.156.
The client sent us the supplier’s factory inspection report and said: “Look, all the heavy metals passed.”
We replied: “The report is valid, but it establishes whether this can of ink contains lead, cadmium, chromium, arsenic, or mercury. It does not establish how much of the printed ink will migrate into food after it is printed onto paperboard and placed in contact with food.”
One of our most typical failures involved a client using an indirect-contact ink whose supplier report showed that all five heavy metals complied, with no abnormalities during production. However, the ink had been printed on a small paper pouch used to hold tea bags, with no barrier between the printed ink layer and the tea bag. The finished pouch subsequently failed the migration test. The ink itself complied, but after being applied to the paper substrate and placed in prolonged contact with food, the migrated amount converted into mg/dm² was not the same matter.
Therefore, when accepting an order, printers should request two sets of documents, not one. Before printing, obtain the ink’s category declaration, inspection report, and list of permitted substrates and printing processes. When confirming the material combination after proofing, establish the scope of the migration-test report for the printed ink layer: who will conduct the testing, what will be tested, and how GB 31604.1 and GB 5009.156 will be applied. When a client says, “The ink has a test report,” they often mean only the first set.
There is also the layer of GB 31603. Clause 4.4 requires the production and printing of inks for food-contact materials and articles to comply with the relevant provisions of GB 31603. Production enterprises and printing enterprises should control the safety risks of ink products through formula design, raw-material selection, production-process control, product-information communication, and other measures. In other words, whether an ink complies is not merely a matter of the can purchased by the procurement department. It also depends on how well the printing process is controlled at the printing company.
Third Boundary: Aromatic Primary Amines Must Not Be Detected—The Strictest Requirement, but with a Narrow Trigger
Among the migration requirements above, one leaves virtually no room for interpretation: aromatic primary amine migration must not be detected, with a detection limit of 0.01 mg/kg. This does not mean that the result must be below a specified number; it means that it must not be detectable.
However, this requirement does not apply to every ink. The footnote to the standard states clearly: It applies only to printed ink layers containing aromatic isocyanates, azo colorants, or other substances that may produce aromatic primary amines. Testing for aromatic primary amine migration must be conducted on the finished food-contact material or article after the ink has dried and its curing reaction has been completed.
Two key terms are involved: the trigger and the timing.
With respect to the trigger, phthalocyanine organic pigments are among the most commonly cited examples in the industry. Phthalocyanine blue and phthalocyanine green can hydrolyze in a dispersion and produce aromatic primary amines. If a client uses an ink with this colorant system—especially a cyan-green or light-blue shade—the printer should proactively ask what colorant system the ink uses and whether this testing has been performed.
With respect to timing, the phrase “after the ink has dried and the curing reaction has been completed” is a strict requirement. If UV-cured ink has not received sufficient curing energy, cross-linking will be incomplete, and the unreacted components may create a safety risk. This is why the standard identifies the finished product, rather than an intermediate product from the printing process, as the test object. Failure to detect a problem in a semi-finished product does not mean that the finished product complies.
The client said: “Our color is fairly light. Light colors should be fine, right?”
We replied: “A lighter shade does not mean the requirement does not apply. Light blue and cyan-green are precisely the shades most likely to fall within this requirement. What needs to be checked is the colorant system, not the color’s lightness.”
There is also an easily overlooked linkage: the standard states that where relevant food-safety national standards and announcements specify migration limits for aromatic primary amines, those limits apply in accordance with the relevant provisions. Before submitting samples for testing, the printer should first confirm which announcement the testing laboratory will use as the basis for judgment rather than estimating a limit independently.
Another Easily Missed Requirement: Sensory Characteristics Are the First Gate
The sensory requirements of GB 4806.14 appear before the physical and chemical requirements and address two matters: food-contact materials and articles printed with ink must have an ink layer that does not shed or stick, has no off-odors, and contains no unclean matter; the immersion liquid obtained from migration testing must not show abnormal coloration, turbidity, sediment, off-odors, or other deterioration in sensory properties. The latter applies only to printed ink layers in direct contact with food.
Sensory performance is generally the first issue that can be detected. When clients complain that “opening the package gives off a strong ink odor,” we generally find that three issues have overlapped: the ink selection is unsuitable for the particular system, curing is insufficient, or a downstream lamination process has trapped volatile substances inside.
We would also like to remind clients of a particular requirement: the standard requires ink manufacturers to control the safety risks of ink products through formula design, raw-material selection, production-process control, product-information communication, and other measures. In the compliance chain, the printing company is the user rather than the responsible manufacturer, but the standard also requires printers to control risks through their own printing-process controls. A problem at the ink manufacturer is the ink manufacturer’s responsibility, but printing the ink in the wrong location or failing to cure it adequately remains the printer’s responsibility.
When a Printer Receives an Inquiry About Whether Ink Can Be Used on a Food Box, What Should Be Checked First?
If these three matters are resolved, the rest can be addressed afterward.
First: Determine whether the printed surface is in direct or indirect contact with food. A single question—“inside or outside?”—can settle it. For direct contact, the ink supplier must provide a statement demonstrating compliance of raw materials and additives with the GB 2760 framework. For indirect contact, the supplier must provide a statement demonstrating compliance of colorant purity with GB 9685 and confirm that no lead-, mercury-, cadmium-, chromium-, arsenic-, or selenium-based colorants are used.
Second: Request two sets of documents, not one. One set consists of the ink’s category declaration, inspection report, and list of permitted substrates and printing processes. The other concerns the migration-testing scope for the printed ink layer: who will conduct the test, what will be tested, and how GB 31604.1 and GB 5009.156 will be applied.
Third: Lock in the testing plan in advance for inks that trigger the aromatic-primary-amine requirement. If the ink contains a phthalocyanine organic pigment, or the supplier’s raw-material documentation mentions aromatic isocyanates or azo colorants, the retesting plan should be finalized before the order is placed. The test object must be the finished product after curing.
Once these three questions have been answered, we can discuss price. Price negotiations cannot resolve the problem that a client believed a report existed when it did not.
A Message for Clients
Regarding inks for food contact, the most important message we want to send clients is: “Please replace ‘food-grade ink’ with ‘GB 4806.14 [specified category] ink, suitable for [specified substrate], using [specified printing process].’”
The first formulation cannot be executed. The second can be used directly for ordering, incoming inspection, and testing.
The client said: “But suppliers will not write anything that detailed.”
We replied: “Then we can send the supplier an email together and list the items required by Clause 6.2.2. This usually takes ten minutes to resolve and saves weeks of dispute later.”
Further Reading
- Three Practical Boundaries for Determining Ink Migration in Food Packaging—the relationship among total migration, heavy metals, and shelf life
- GB 31604 vs. EU Regulation 10/2011 for Food-Contact Packaging Migration—differences in migration-testing frameworks for export orders
- Three Practical Boundaries of GB 4806.15 for Adhesives Used in Food Contact—another regulated component in the same package on adhesive-lamination orders
- Three Practical Classifications of Packaging Test Reports—which reports can genuinely protect a printer from liability
FAQ
Is the statement on the ink supplier’s instructions that the ink “complies with food-contact standards” sufficient?
No, although it is a starting point. Clause 6.2.2 of GB 4806.14-2023 requires ink products to identify three types of information on the label or accompanying documents: the product category—ink for direct contact with food or ink for indirect contact with food; the recommended printing substrates; and the printing process, such as curing time, together with any special use requirements. Instructions stating only that the ink “complies with food-contact standards” omit all three. Printers need information that can be used directly for ordering, incoming inspection, and testing: category, substrate list, and process parameters. If all three are present, work can proceed; if one is missing, request it from the ink supplier, which will usually take about ten minutes to resolve.
What happens if direct and indirect contact are classified incorrectly?
There are two levels of consequence. From a compliance perspective, if an indirect-contact ink that meets only the GB 9685 framework is used on a direct-contact surface, its raw materials do not meet the GB 2760 requirements, and the packaging does not satisfy food-contact compliance. The finished packaging is therefore likely to fail total-migration or specific-migration testing. From a production perspective, misidentifying the position also affects process requirements. A direct-contact surface means that the ink layer will ultimately remain with the food, so drying and curing requirements are more stringent. Insufficient UV-curing energy is more likely to be exposed on such surfaces. We therefore do not rely on the client to make this determination and simply ask whether the printed surface is inside or outside.
All five heavy metals in the ink inspection report passed. Why might the printed product still fail testing?
Because the two sets of requirements assess different objects. Clause 5.3.1.1 covers the ink itself, with heavy-metal residues calculated on the ink’s dry weight: Pb ≤10, Hg ≤10, Cd ≤5, Cr ≤25, and As ≤5 mg/kg. Clause 5.3.1.2 covers the printed ink layer and requires migration testing of the finished printed product under GB 31604.1 and GB 5009.156. Its results include total migration ≤10 mg/dm², or ≤60 mg/kg for products specifically intended for infants and young children; potassium permanganate consumption ≤10 mg/kg; and heavy metals expressed as Pb ≤1 mg/kg. These figures do not have a direct conversion relationship. Compliance of the ink itself does not establish compliance after printing, because the substrate, ink coverage, and curing conditions are additional variables. When requesting documents from a client, specify which set is needed.
When is aromatic-primary-amine testing mandatory?
Two conditions must both be met. First, the ink contains colorants capable of producing aromatic primary amines, specifically aromatic isocyanates and azo colorants identified in the standard’s footnote; common examples in practice are phthalocyanine organic pigments such as phthalocyanine blue and phthalocyanine green. Second, the relevant layer is a printed ink layer. Once triggered, testing must be conducted on the finished product after the ink has dried and its curing reaction has been completed, using a detection limit of 0.01 mg/kg, with no detection permitted. The test object is the finished product rather than a semi-finished item, because problems caused by incompletely cross-linked ink are revealed in the cured finished product.
Who should submit the samples for migration testing, and when should testing be conducted?
Three arrangements are common, but their boundaries differ. First, the printer may submit the complete material combination—paper substrate, ink, varnish, and lamination—for a preliminary migration test during proofing, preventing material-selection errors before mass production. Second, after production and delivery, the client may commission a third-party laboratory for export or retail-channel qualification; the client is the commissioning party, and the printer assists by providing samples. Third, the client may designate the printer as the commissioning party and include the testing charge in the order, in which case the ownership of testing costs and the handling of retesting should be stated in the quotation in advance. We recommend that printers commission a preliminary test during proofing, because the cost of rework after mass production is far greater than the cost of one test.
What should we do if the client insists on a solid dark background and the package structure cannot include a barrier layer?
First confirm whether the surface is in direct contact with food. If it is only the outer surface and therefore involves indirect contact, GB 4806.14 permits a broader range of raw materials for indirect-contact inks than for direct-contact inks, but it still prohibits colorants based on lead, mercury, cadmium, chromium, arsenic, or selenium, and the ink supplier must provide a compliance statement. If the surface is genuinely in direct contact with food, there is no basis for insisting on unrestricted ink coverage. Clause 4.3 requires printing enterprises to minimize ink use as far as possible while achieving the intended printing effect. Practical measures include replacing a solid background with partial ink coverage or lower dot coverage, checking whether the color falls within the trigger for aromatic-primary-amine testing, and changing the downstream lamination to a structure that reduces contact between the ink layer and food. If the structure cannot be changed, the only option is to replace the entire material combination.
📚 📚 Related Recommendations
Need a Custom Packaging Solution?
Learn more about packaging, or consult directly for a custom solution and quote