QS Audit Rules for Food-Use Plastic Packaging: Supplementary Interpretations Refine Application Materials, Environmental Certificates and On-Site Verification

The professional committee has issued supplementary interpretations of the General Rules and the Detailed Rules for food packaging materials, setting out clearer criteria for how food-use plastic packaging containers, tools and similar products are handled at the stages of licence application, on-site verification and product testing.

Item 1 — For the materials submitted by enterprises under Clause 3.1.2 of the General Rules, two additions are required: a photocopy of the enterprise's organisation code certificate and its filed enterprise standard.

Item 2 — Clause 3.1.2.2, photocopy of the business licence: when a food production enterprise applies for a production licence for food-use plastic packaging containers, tools and other products, and the business scope on its business licence covers only the food it produces, no requirement is imposed on the food-use plastic packaging containers, tools and other products it produces for its own use.

Item 3 — Clause 3.1.2.3, certification documents meeting the requirements issued by the local environmental protection department: the requirement has been eased, and any one of the following three is acceptable — (1) the environmental protection department's approval opinion on the enterprise's construction project, issued on the basis of the environmental impact assessment report, together with its acceptance opinion after the plant was built; (2) a pollutant discharge permit plus proof of noise compliance; (3) an environmental monitoring report.

Item 4 — Clause 3.1.2.7, product type test reports. (1) The report may be completed by the enterprise itself or commissioned to a qualified testing institution, but it must relate to the same batch of products, meaning all test items appear in a single report. (2) If the enterprise cannot present the type test report at the verification site, the verification team continues with the on-site verification work, but the enterprise must submit the report within the prescribed time; otherwise the submitted materials are deemed incomplete.

Item 5 — Clause 3.1.2.8, product instructions or product labels. Enterprises may draft these according to the characteristics of their own products: any content affecting personal health and safety must be stated, while other self-evident content may be simplified — provided that such simplification does not cause inconvenience or harm to users.

Item 6 — Clause 3.2.2, products from trial production. These must undergo batch-by-batch inspection by testing institutions designated by the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) in accordance with the applicable product rules. The eight certification testing institutions designated by the Administration carry out batch-by-batch inspection of factory-exit test items. "Products from trial production" here covers both the products of newly built enterprises and the added products of enterprises that already hold certification.

Item 7 — Where an enterprise lacks the capacity to test key control items, it must send samples for testing every three months to a testing institution designated by AQSIQ. The designated testing institutions referred to are the certification testing institutions specified in Document No. 86.

Item 8 — Clause 7.6, the situation where a product fails test items during spot checks, supervision inspections or after a complaint about its quality: the "spot checks and supervision inspections" mentioned above cover provincial supervision spot checks, periodic municipal and prefectural supervision spot checks, national supervision spot checks and special inspections, among other forms.

Item 9 — The on-site verification method under the Detailed Rules lays down specific requirements for enterprises that handle only part of the production process, such as bag-making plants, repackaging plants and assembly plants: (1) the requirements for on-site verification, production equipment and testing equipment cover only the content involved in that process; (2) the production licence certificate of such enterprises will indicate the limited process under the product variety; (3) for bag-making plants and repackaging plants, a type test report on a product from an upstream enterprise may be recognised, and after on-site verification is passed, samples still have to be drawn for certification testing.

Clause 2.2.8 requires workshops to establish separate routes for personnel entry and exit and for material logistics; entry points for personnel should have disinfection, dust removal or air shower (bath) devices, and work clothing should be kept clean. Every producer of food-use plastic packaging containers, tools and similar products must have both personnel and logistics routes: the personnel route should include changing, disinfection and dust removal facilities, while the logistics route should be isolated from the production area and include an isolation zone suited to production. Personnel transporting materials may not enter the production area, and workers in the production area may not enter or leave through the logistics route.

For producers of packaging containers, tools and similar products that directly wrap food for oral consumption — cling film, laminated film, disposable tableware, beverage bottles or drinking water buckets, for example — separate requirements apply to disinfection facilities, such as hand washing … (the original text is longer; an excerpt is given here).