CHINA FCM COMPLIANCE UPDATE
On August 12, 2026, China's Defective Product Recall Center published a recall notice stating that Shanghai Youjia Technology Co., Ltd. would recall 1,500 Youjia kitchen towels because of excessive acrylamide content. The affected two-ply towels measured 210 x 195 mm and were manufactured on January 21, 2026. Consumers were advised to stop using the product immediately, and the recall was scheduled to run from August 14 to November 13, 2026.
The product declared compliance with GB/T 26174-2023, Kitchen Towel, which sets an acrylamide content limit of 0.1 mg/kg for kitchen towels. The recall therefore concerns a clear product-standard failure. It also raises a broader question for manufacturers and brand owners: when a kitchen towel is intended to touch food directly, is GB/T 26174-2023 enough?
The short answer is no. If a product is marketed or intended for direct food contact - for example, to absorb moisture from raw meat, remove oil from fried food, or wrap food - it should also be assessed under China's food contact materials (FCM) framework, including GB 4806.8-2022 and other standards that apply to its composition and conditions of use. Companies planning this type of market positioning can review REACH24H's China food contact materials compliance services.
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Why the Intended Use of Kitchen Paper Matters
GB/T 26174-2023 primarily addresses kitchen towels used for wiping and cleaning in the kitchen, such as cleaning worktops and utensils or removing water and grease. In practice, consumers may also use kitchen paper to dry ingredients, absorb oil from cooked foods, or wrap vegetables and ready-to-eat foods. These uses create direct contact between the paper and food.
For compliance planning, the key question is not the product name alone. Companies should examine the intended and reasonably foreseeable conditions of use reflected in the product design, packaging, instructions, claims, and marketing images. An incidental off-label consumer use does not by itself rewrite a manufacturer's declared product scope. However, if the product is presented as suitable for direct food contact, its specifications and supporting evidence should address that use.
GB/T 26174-2023 and GB 4806.8-2022 are therefore not substitutes. They address different regulatory questions and may apply together when a kitchen towel is also intended for food contact.
GB/T 26174-2023 vs. GB 4806.8-2022
| Point | GB/T 26174-2023 | GB 4806.8-2022 |
|---|---|---|
| Role | Recommended national product standard for kitchen towels | Mandatory national food safety standard for paper and paperboard materials and articles intended for food contact |
| Primary scenario | Kitchen wiping and cleaning | Direct or indirect food contact under intended conditions of use |
| Main control focus | Product quality and safety parameters, including acrylamide content | Raw materials, additives, sensory properties, migration, residues, microbiological limits, and product information |
| Acrylamide point | Acrylamide content in the towel: no more than 0.1 mg/kg | Acrylamide may also be controlled through additive authorization and specific migration restrictions under GB 9685 |
| Related standards | Product-specific requirements | GB 4806.1, GB 9685, applicable NHC announcements, and standards for coatings, inks, adhesives, or composite structures where relevant |
| Does one replace the other? | No | No; a product intended for both kitchen-towel use and food contact may need to satisfy both sets of requirements |
What GB 4806.8 Adds for Food-Contact Paper
Food-contact paper is rarely only cellulose fiber. Depending on the intended performance, manufacturers may use wet-strength agents, absorbency aids, grease-resistant treatments, surface coatings, printing inks, or adhesives. GB 4806.8-2022 therefore requires more than checking a few finished-product indicators. A defensible assessment starts with the paper substrate and extends to additives and surface functional layers.
Paper and paperboard materials and articles must meet GB 4806.8-2022. Additives used in their manufacture must comply with GB 9685-2016 and relevant National Health Commission (NHC) announcements. Where coatings, inks, adhesives, or composite structures are present, the corresponding standards may also apply, including GB 4806.10, GB 4806.14, GB 4806.15, or GB 4806.13, as relevant.
| Control Item | GB 4806.8-2022 Requirement |
|---|---|
| Sensory - paper and paperboard | Normal color; no abnormal odor, mildew, or other contamination |
| Sensory - migration test solution | No abnormal coloration, odor, or other deterioration of sensory properties |
| Overall migration | ≤10 mg/dm2; 60 mg/kg for materials and articles specifically intended for infants and young children |
| Heavy metal migration (as Pb) | ≤1 mg/kg; applicable only to products intended to contact aqueous foods |
| Lead residue | ≤3.0 mg/kg |
| Arsenic residue | ≤1.0 mg/kg |
| Fluorescent substances | Negative at both 254 nm and 365 nm |
| Formaldehyde residue | ≤1.0 mg/dm2 |
| 1,3-Dichloro-2-propanol residue | Not detected; detection limit 2 µg/L |
| 3-Chloro-1,2-propanediol residue | ≤12 µg/L |
| Coliforms | Not detected in 50 cm2 |
| Salmonella | Not detected in 50 cm2 |
| Mould | ≤50 CFU/g* |
* Note: The microbiological requirements apply to paper and paperboard intended for direct food contact and used without disinfection or washing. The standard provides an exception for products contacting foods that will be peeled, shelled, or washed before consumption, cooking, or processing.
Food-Contact Paper Also Requires Additive Screening under GB 9685
Compliance with GB 4806.8-2022 does not mean every chemical used in the paper may be used without restriction. GB 9685-2016 manages additives for food contact materials through positive lists. For each additive, companies should confirm whether it is authorized for paper and paperboard and then check the permitted material category, maximum use level, specific migration limit (SML), maximum residual quantity (QM), and any other restrictions.
Examples of GB 9685 entries relevant to acrylamide-based paper additives include:
| Substance Example | CAS No. | Max. Use | Acrylamide Restriction |
|---|---|---|---|
| Acrylic acid-acrylamide copolymer | 9003-06-9 | 0.1% | SML: not detected; detection limit 0.01 mg/kg |
| Acrylic acid-acrylamide-sodium acrylate copolymer | 62649-23-4 | 0.1% | SML: not detected; detection limit 0.01 mg/kg |
| Acrylamide-sodium acrylate copolymer | 25085-02-3 | 0.1% | SML: not detected; detection limit 0.01 mg/kg |
Important distinction: the ≤0.1 mg/kg value in GB/T 26174-2023 is a content limit for acrylamide in the kitchen towel. The "not detected at 0.01 mg/kg" entries above are SML requirements that assess migration of acrylamide from the food-contact material into food or a food simulant. These values control different endpoints and should not be treated as interchangeable.
What Manufacturers and Exporters Should Review
Define the intended conditions of use. Specify whether contact is direct or indirect, the food types, contact time and temperature, single-use or repeated-use conditions, and whether the product is used without washing or disinfection.
Align claims with the technical specification. Packaging statements, instructions, e-commerce images, and sales materials should not imply food-contact suitability unless the product has been assessed for that use.
Map the full material structure. Identify the fiber source, additives, wet-strength agents, coatings, inks, adhesives, and any laminated or composite layers.
Screen substances before testing. Check additives and other intentionally used substances against GB 9685, applicable product standards, and NHC announcements, including use levels and restrictions.
Design evidence around the actual use scenario. Determine the applicable migration, residue, sensory, and microbiological items after the regulatory and formulation review, rather than relying on a generic test package.
Prepare supply-chain documentation. Collect supplier declarations and supporting information, address restricted substances, and prepare or review the China FCM Declaration of Compliance (DoC).
For a closer look at supply-chain documentation, see REACH24H's guide to the China FCM Declaration of Compliance.
How REACH24H Can Help
REACH24H supports manufacturers, exporters, brand owners, importers, and material suppliers in evaluating food-contact products for the China market. Support can be tailored to the product and may include:
Intended-use review and identification of applicable China FCM standards
Formulation and additive screening, including new-substance determination where needed
Testing-strategy design, laboratory selection, and testing supervision
China FCM DoC preparation or audit and supplier-information review
Need Support with China Food-Contact Paper Compliance?
Discuss your kitchen towel, food-contact paper, paperboard, coating, ink, adhesive, or other China FCM project with REACH24H.
Recommended Reading
Understanding China's Declaration of Compliance for Food Contact Materials
China GB 4806.7-2023 Food Contact Plastics: Key Compliance Updates
