GB 31604 vs EU 10/2011 for food-contact packaging migration: 3 real boundaries print shops miss
In November 2024, a client in Suzhou making baby food came to me. Their new product was planned for both the domestic e-commerce channel and the European Amazon channel. The packaging used a PE inner bag from the same supplier. The client asked: 'Can I do just one test report and use it both at home and abroad?'
I said directly: no. GB 31604 and EU 10/2011 differ fundamentally on 3 dimensions, and a single report covering both markets will be rejected by EU customs when goods are inspected.
This article lays out those 3 differences—not in legal article language, but in practical decision methods the print shop can actually use on the production floor.
1. Different test conditions: temperature × time × simulant combinations differ
The GB 31604 series defines migration test conditions as 'choose according to actual use,' without mandating which food simulant to use. But the default practice of domestic third-party testing bodies (SGS, CTI, Pony) is 4 simulants: water-based (10% ethanol), acidic (4% acetic acid), oil-based (olive oil or 95% ethanol substitute), fatty (isooctane). Common temperatures are 40°C × 10 days or 70°C × 2 hours.
EU 10/2011 is stricter. The EU specifies 6 food simulants: A (water), B (3% acetic acid), C (10% ethanol), D1 (50% ethanol), D2 (vegetable oil), E (polydimethylsiloxane PDMS for frozen food testing). Simulant selection is based on the actual food type being contacted—alcoholic beverages must use D1, oily foods must use D2.
Real case: a Shanghai client making sauce packaging, the inner layer is PET, contacting a 15% oil-content tomato sauce. Domestic testing used C simulant (10% ethanol) at 70°C × 2 hours, migration 5.8 mg/dm², just under the GB limit of 10 mg/dm². The client took that report and tried to export to the EU, was sampled by customs and asked to run D2 testing—under olive oil simulant migration was 18 mg/dm², exceeding the limit by 1.8 times. They had to switch the barrier layer material.
Practical rule: if a client sells both domestically and in the EU, they must submit samples separately—when submitting, actively inform the testing body of the food type, and the third party will supplement tests with D1/D2 simulants per EU 10/2011.
2. Different limit values: tolerance gaps for the same substance between markets
GB 31604.1 sets the overall migration limit (OML) at 10 mg/dm². EU 10/2011's OML is also 10 mg/dm²—the numbers look consistent. But for specific substance SMLs (specific migration limits), the two regulations differ on tolerance for the same substance.
Example: phthalate plasticizers (DBP, BBP, DEHP, DIOP)—GB 4806.7 (plastic food-contact materials) allows DEHP a limit of 1.5 mg/kg in certain scenarios, EU 10/2011's SML for DEHP is 0.6 mg/kg.
Another more typical example: Bisphenol A (BPA). China's GB 4806.10 sets the SML for BPA in polycarbonate baby bottles at 0.6 mg/kg. EU 10/2011's SML for BPA is 0.05 mg/kg—12 times lower. In 2024 the EU further classified BPA as CMR 1B (carcinogenic, mutagenic, toxic to reproduction), and is moving toward a full ban.
The trap for print shops: color masterbatch or ink provided by the client contains BPA (many UV-curing inks use BPA as epoxy resin raw material). Tested per GB for domestic sale it passes, tested per EU for export it blows up. When a print shop takes an EU export order, it must ask the ink supplier for a BPA declaration.
Practical rule: for EU orders, BPA-free and phthalate-free declarations must be obtained for inks, glues, and masterbatch. Both declarations are not decorations—they are customs clearance documents for EU customs.
3. Report validity period and testing-body qualification differences
For GB 31604 series test reports, the domestic default validity is 1 year (many testing bodies write 3 years but actual contract terms default to 1 year). EU 10/2011 does not state a validity period explicitly, but EU customs will randomly check whether the report is older than 1 year—reports over 1 year old may be required to be retested.
On testing-body qualifications, domestic bodies doing GB 31604 (SGS, CTI, Pony) hold CMA (China Metrology Accreditation); EU customs-recognized testing bodies must hold ISO 17025 certification + ILAC mutual recognition. Most domestic testing bodies hold both CMA and ISO 17025, but the report format must follow EN 1186 (EU food-contact material migration test method), not GB/T 5009 series.
Real case: a Ningbo factory making baby food used a local testing body for their PE bag testing. The body issued the report citing GB 31604.1 conclusions, but in GB/T 5009.156 format—the client took that report to German customs, customs said the test method was not per EN standard, so it was invalid. Retesting took 6 weeks + ¥28,000.
Practical rule: before submitting samples for EU orders, explicitly require the testing body to 'issue report per EN 1186 method + stamp ISO 17025 + note ILAC number.' Customs recognizes only reports with all three.
4. The 3 real boundaries the print shop faces: things the client does not know to ask you
First, who does the ink migration test. Many clients assume that 'food-grade ink' provided by the packaging factory automatically passes EU testing. In fact, whether the ink has done migration testing depends on whether the ink supplier has EU EFSA certification. The print shop, when choosing ink, must ask the supplier for the EFSA assessment file—this file is the core evidence when EU customs spot-checks.
Second, choice of lamination adhesive. Adhesives for food-contact packaging composite films commonly use solvent-free polyurethane in China, but EU 10/2011 has limit requirements for primary aromatic amines (PAA) in adhesives. Many domestic adhesive suppliers only did GB testing, not EU testing. The print shop, when receiving adhesive, must obtain the PAA test report.
Third, secondary contamination from post-printing processes. The printed pattern on packaging goes through laminating, die-cutting, foil stamping, UV and other post-press processes. The glues, inks, UV varnish used in these processes are not in the food-contact layer—seemingly no problem—but the trim migration at die-cut and toluene residue from printing ink may both be detected in EU testing. When the print shop takes export orders, every post-press material must have a food-grade declaration.
5. What the print shop can do for the client, what it cannot
Can do for the client:
1) Help the client choose ink and glue, proactively provide BPA-free / PAA-free / EU 10/2011 compatibility declaration documents. The client does not need to understand these chemical names.
2) Help the client judge 'is this order for domestic or export sale,' and if export, suggest separate SKU inner-layer materials to avoid one package needing both GB and EU.
3) Help the client connect with testing bodies. Major domestic third parties all do food-contact work; the print shop can tell the client which testing body has CMA + ISO 17025 + EN 1186 capability.
Cannot do for the client:
1) Issue the test report for the client. Test reports must come from third parties; the print shop cannot self-test and self-judge.
2) Sign the compliance declaration for the client. The compliance responsibility for food-contact lies with the food producer (the client), not the print shop. What the print shop can provide is the material compliance certificate, certifying that the ink/glue/paper/film we use is compliant.
3) Guarantee 'definitely passes EU customs.' The print shop can only ensure material compliance; final customs clearance depends on the customs spot-check result and the client's own product formulation.
The client's reasonable expectation of the print shop is: I help you pick the right materials, complete the documentation, match the testing method. But 'compliance customs clearance' is something the client also needs someone dedicated to track.
6. Cost boundary of export food packaging compliance: how much extra does compliance really cost
This is what clients most often ask. To be honest: for a ¥100,000 food packaging order, EU compliance costs more than GB compliance—
1) Testing fees: GB report ¥8,000-12,000, EU report ¥15,000-25,000 (per EN 1186 method), extra ¥7,000-13,000.
2) Material upgrade: BPA-free ink is 15-25% more expensive than standard ink, PAA-free adhesive is 8-15% more. Overall material cost rises 5-12%.
3) Documentation: compliance documents (ink declaration, adhesive declaration, barrier layer declaration) the print shop helps the client produce cost about ¥2,000-5,000 (one-time).
Total: EU compliance premium for one order is roughly 8-15% of the order total. If the client's order margin is under 15%, EU compliance basically does not make money, and the order price must be raised or the EU market abandoned.
If you are evaluating the export compliance cost of a food packaging order, you can send us the order amount, SKU count, and target market, and we can give you a compliance checklist and cost estimate within 1 hour.
Further reading
GB 4806.1 to 4806.11 — clearing it up in one article
GB 4806 food-contact packaging testing projects in practice
FAQ
What is the relationship between GB 31604 and GB 4806?
GB 4806 is the product standard, specifying the safety requirements and test items for each material (plastic/rubber/paper/metal); GB 31604 is the method standard, specifying how each test is performed (e.g., how to measure migration, how to test sensory). A complete food-contact material test report must include the items referenced by GB 4806 plus the methods referenced by GB 31604. The two are used together; both are required. A client saying only 'do a GB 4806 test' is incomplete; you must specify the GB 4806 material number (e.g., 4806.7 plastic) plus the corresponding GB 31604 method number.
Why is an EU report for PE bags twice the price of a GB report?
EU 10/2011 requires testing per the EN 1186 series of methods, with higher demands on equipment and experimental environment (temperature precision ±0.5°C, migration cell specifications per EN 13130), so laboratory investment is large. GB/T 5009.156 is the domestic method, with general-purpose equipment and lower cost. A complete EU food-contact report (6 simulants + 4 temperature combinations + total migration + specific migration) takes 2.5-3 times the lab hours of a GB report, so the quotation is about twice the price.
Is the client's 'food-grade ink' declaration enough?
Not enough. The 'food-grade ink' declaration on the Chinese market is usually based on the GB 4806.1 framework but has not done EU 10/2011-specific migration testing. EU export orders need the 'EFSA assessment file' (European Food Safety Authority substance evaluation conclusion) + 'BPA-free declaration' + 'PAA-free declaration.' Any one missing may result in EU customs returning the goods. The print shop must proactively request these when receiving ink, not wait for the client to ask.
Why does the same packaging inner layer material pass GB but fail EU?
The two markets choose different food simulants. For example, for oily food, domestic testing uses C simulant (10% ethanol), EU testing uses D2 simulant (olive oil). Olive oil has a much stronger swelling effect on plastic than 10% ethanol, and can dissolve out more substances. The same plastic migrating 5 mg/dm² in 10% ethanol may migrate 15 mg/dm² in olive oil. That is the most common reason for 'GB pass but EU fail'—not because the material itself is toxic, but because the test conditions differ.
Can the print shop do EU testing for the client?
No. Food-contact material test reports must be issued by third-party testing bodies holding CMA (China) or ISO 17025 + ILAC mutual recognition (EU). The print shop has no testing qualifications and is not allowed to self-test and self-judge. What the print shop can do: 1) help the client choose compliant materials (ink/glue/paper/film); 2) help the client connect with suitable testing bodies; 3) help the client organize compliance documentation. The testing itself must be sent to a third party.
How long is the EU report valid?
EU 10/2011 itself does not specify a clear report validity period. In practice, EU customs requires retesting or supplemental declarations for reports older than 12 months (depending on product category and company credibility). So we recommend treating the EU report as valid for 1 year and retesting annually. Some large clients (Nestle, Danone) require suppliers to provide a new material declaration every six months—this is an enterprise internal rule, not a regulatory requirement.
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