3 Types of Production License Changes for Food Packaging Plants: The Real Transition Path for SC / QS / SC-GMP

A printing plant owner in Wuxin who makes pastry boxes came to me last November. He had been supplying mooncake gift box packaging to a mooncake contract manufacturer for 8 years, and this year the client suddenly said, "We need to change our QS license to an SC license—can you provide us with a new material compliance certificate to match?" He took his QS copy to the market regulation bureau, and the staff told him, "QS licenses stopped being issued in 2015. Whether your printing plant holds a QS is your own business, but your client's SC license has nothing to do with your printing plant."

This may sound convoluted, but it accurately reflects the biggest compliance fog in the food packaging industry: Does a printing plant need to apply for an SC license? Is the QS license still valid? What exactly is SC-GMP? How do these three license types correspond to different business scenarios at a food packaging printing plant?

Type 1: SC License — Does a Printing Plant Need to Apply?

The SC license (full name "Food Production License") replaced the QS license starting in 2015. But the SC license is issued to food production enterprises, not to packaging printing plants. This is the most commonly confused step.

Printing plants do NOT need to apply for an SC license—because printing plants are not food production enterprises. Printing plants are "food-related product production enterprises," governed by the "Food-Related Product Production License" (also called "Industrial Product Production License").

What food packaging printing plants need to apply for is the "Food-Related Product Production License", covering categories including: food packaging paper, plastic products for food packaging, composite film/bags for food packaging, food-related tools and equipment, etc. The specific category depends on the printing plant's main products.

A common misconception among printing plant owners in practice: seeing that clients have SC licenses, they go apply for an SC license themselves—only to have the market regulation bureau reject the application, wasting time. The correct path is to go to the "Industrial Product Production License" window at the local market regulation bureau and file under "food-related products."

Type 2: QS License — Is the One in Your Hands Still Valid?

The QS license stopped being issued starting in 2015, and fully exited the food market from October 1, 2018. But if a printing plant still has QS copies issued before 2015, can they continue to be used?

The answer is: it depends on the specific category. For "food-related products" such as food packaging paper and plastic products, the QS license has been completely invalid since 2018. QS licenses for food items (the contents themselves) are also completely invalid after 2018.

However, printing plants may still encounter QS copies when interfacing with clients—these are mostly historical records from licenses food factories obtained before 2015 and now exist only as archives. When taking orders from such clients, the printing plant should proactively confirm whether the client is "currently in license transition" or "operating without a valid license." License transition falls under a grace period and business can continue; operating without a license is a violation and orders should be declined.

Type 3: SC-GMP Review — Which Food Packaging Must Pass?

SC-GMP is the "Good Manufacturing Practice" review layered on top of the SC license from 2018 onward, mainly targeting high-risk food categories such as infant formula, foods for special medical purposes, and health foods.

But since 2020, market regulation bureaus in some provinces have begun extending SC-GMP reviews to "packaging in direct contact with high-risk foods"—meaning when a food factory applies for SC-GMP, its packaging suppliers' production environment, quality management system, and microbial control capabilities are also reviewed.

This "extended review" is not yet nationally unified, but the four major food industry provinces—Jiangsu, Zhejiang, Guangdong, and Fujian—have already implemented it. If a printing plant supplies packaging for infant formula, complementary foods, or health foods, it will almost certainly be required by the client to undergo an SC-GMP extended review.

What a printing plant needs to prepare in practice: ① Production environment reaching Grade 300,000 or higher cleanliness (not mandatory, but a plus); ② Establish microbial testing records; ③ Operating SOPs for key positions (printing, laminating, die-cutting); ④ Ability to provide water quality test reports for the past 6 months (tap water is acceptable). Together, these are 3-5 times more complex than simply obtaining an SC license.

3 New Requirements for Printing Plants in the 2025 "General Rules for Food Production License Review"

The 2025 new version of the General Rules introduces three categories of new requirements worth attention for food packaging printing plants:

The first is "contract processing" filing. If a printing plant processes packaging on behalf of a food factory (rather than selling directly to end users), it must note "contract processing" on its food-related product production license and provide copies of the client's qualifications.

The second is "formula filing". Food packaging inks, glues, composite adhesives, etc. require ingredient lists and supplier qualifications to facilitate traceability by the market regulation bureau.

The third is "batch-by-batch inspection". The new General Rules require food packaging printing plants to conduct microbial indicator spot-checks (total colony count, coliform bacteria) on every batch of finished products, with test reports retained for at least 3 years.

3 Practical Tips for Printing Plants Applying for Licenses

First, clarify whether you fall under "food-related products" or "ordinary industrial products". If more than 50% of a printing plant's orders are food packaging, apply for the food-related product production license; if food packaging is only occasional, applying under ordinary industrial products is sufficient.

Second, do not proactively apply for SC-GMP. SC-GMP is the food factory's responsibility—the printing plant is the subject of an extended review. Only when a client explicitly states "we need to pass SC-GMP, and your packaging qualifications need to match" should you initiate the corresponding preparation.

Third, the "batch-by-batch inspection" in the 2025 General Rules is currently the biggest compliance cost. An outsourced microbial test report costs 800-1,500 RMB; if a printing plant produces 50 batches of food packaging per month, testing fees alone will reach 40,000-70,000 RMB/month. It is recommended that printing plants build in-house rapid testing capability (total colony count test strips cost about 2,000 RMB/box, capable of 100 tests), bringing per-test cost down to under 20 RMB.

Further Reading

• Practical Guide to GB 4806 Testing Items for Food Contact Packaging
• How to Read the 9 Standards in the GB 31604 Series for Food Contact Packaging
• 3 Mandatory Requirements of ISO 22000 Food Safety Management Systems for Packaging Plants