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Exclusive Interview with Xiaolu Wang of 3E

Smithers: China is increasingly focused on food safety – what are the implications for food contact regulations?

Xiaolu Wang: While the increased focus on food safety might have various real-world implications, the following two aspects strike me as the most significant for companies operating in the food contact material industry:  

First of all, the coverage and level of complexity of food safety legislation will continue growing, possibly at a higher pace due to the constant demands of safe food products from consumers. As we’ve already witnessed in the last a few years, China issued quite a number of national food safety standards regulating the topics of both food and food contact materials. I do believe that this trend is going to continue until a comprehensive legislative system is established for food safety assurance.

Secondly, government agencies will likely step up the effort in enforcing food safety related laws, regulations. This would be the logical conclusion, if we consider the efforts that the Chinese authorities have already put into enacting new food safety legislation. It has also been proven by the enforcement and inspection plans issued by the Chinese authorities recently.

Smithers: What are the hot topics for food contact in Asia Pacific right now?

Xiaolu Wang: For China, the National Food Safety Standard (GB 9685-2016): Standard for the Use of Additives in Food Contact Materials and Articles came into force in October last year, so it is still relatively new at this point. I would expect certain level of adjustments or even confusion on the manufacturers’ end, which can turn this standard into a hot topic.

For japan, a positive list system for food contact materials is continuously being developed and discussed by the authorities and the industry. Many companies are paying close attention to the current status of this system.

Smithers: What advice do you have for companies looking to achieve food contact compliance in China?

Xiaolu Wang: Generally speaking, language barriers and different legislative frameworks in China are the two major challenges for companies to ensure regulatory compliance. It is particularly difficult for international companies to set up a regulatory compliance scheme worldwide, as it requires multiple language skills and sufficient knowledge of foreign regulatory systems. Furthermore, the lack of access to regulatory information in China might also bring additional challenges for international companies. We do see that the Chinese government has improved tremendously in terms of providing sufficient information to the industry. That being said, due to the language barrier, it would be very difficult, if not impossible, for the government to disclose regulatory information in a foreign language.

In addition to the challenges in understanding the regulatory framework itself, the other difficult situation in which international companies often find themselves is the lack of channels and skills to communicate with the Chinese authorities. Communication with the authorities is an important, and often times, necessary process for carrying out any types of business in China. Lack of knowledge and understanding of the local culture and preferred ways of communication often prevents companies from establishing their business presence efficiently.

The key to achieving compliance with the Chinese FCM regulations is to effectively management all these challenges as I mention above. It is highly advised that companies take the time to fully understand the legal system regulating FCMs in China, including collecting legislative information and reviewing regulatory requirements. They must also ensure necessary processes are implemented to integrate these legal requirements into their daily operations. An open communication channel with the local government authorities would also be highly beneficial to establishing their business presence in China.  

Smithers: Which geographic markets in Asia Pacific are undergoing the most significant changes?

Xiaolu Wang: China, in my opinion, is undoubtedly the market that’s going through significant changes in recent years. The changes can be attributed to many different factors, such as economic growth, technology development, as well as the change of consumption behaviors of the general population. The huge market size also amplifies the impacts caused by these changes.

Smithers: What is the future regulatory outlook in Asia Pacific?

Xiaolu Wang: The level of legislation and enforcement will both increase as the economy grows in this region, possibly significantly.

Smithers: What are you most looking forward to about this year’s conference?

Xiaolu Wang: I am looking forward to learning about the recent developments in the field of food contact materials around the global, including scientific developments, legislative developments, and consumption trends.