GB 4806.10-2025 vs EU 2024/3190:

Side-by-Side Comparison & Practical Differences

Introduction: Two Standards, One Direction — The BPA-Free Era

GB 4806.10-2025 and EU 2024/3190 both restrict BPA in food contact coatings, but with critical differences in migration limits, banned substances, scope and enforcement dates. The EU was the first to publish Regulation (EU) 2024/3190, implementing a comprehensive BPA ban; China followed with GB 4806.10-2025, cutting the BPA migration limit 12-fold. Together, these two standards mark the global entry into the "BPA-free era" for food contact materials.

For sheet metal coating manufacturers serving both domestic and international markets, understanding the differences is essential: export products must meet EU standards, domestic products must meet GB standards, and products targeting both markets must satisfy both. This guide breaks down the comparison and gives a practical compliance strategy.

1. Background of the Two Standards

In late 2024 and early 2025, China and the EU almost simultaneously tightened controls on BPA in food contact coatings. The EU率先 published Regulation (EU) 2024/3190, implementing a comprehensive BPA ban; China followed with GB 4806.10-2025, reducing the BPA migration limit by 12-fold. Together, these standards mark the global entry into the "BPA-free era" for food contact materials.

For sheet metal coating manufacturers serving both domestic and international markets, understanding the differences between these two standards is essential — export products must meet EU standards, domestic products must meet GB standards, and products targeting both markets must satisfy both.

2. Core Comparison Table

3. Five Key Differences Explained

Difference 1: Migration Limit — A 50× Gap

The EU set the BPA migration limit at 1 μg/kg (1 ppb) — a "non-detectable" level that effectively requires BPA to be absent. China's 0.05 mg/kg (50 μg/kg), while 12× stricter than the previous 0.6 mg/kg, is still 50× higher than the EU's. Meeting the Chinese standard does NOT mean meeting the EU standard — export manufacturers must comply with the EU level.

Difference 2: Banned Substance Scope

The EU ban covers BPA, BPS, BPF, BPAF and all CLP-classified 1A/1B CMR or ED bisphenol substances. China currently only restricts BPA itself. This means using BPF to replace BPA may be temporarily compliant for domestic sales (GB doesn't restrict BPF yet), but would be non-compliant for EU export. Given that GB standards will likely follow the EU in expanding scope, we recommend selecting fully bisphenol-free alternative systems now.

Difference 3: Test Method Mutual Recognition

China's GB 31604.5 and the EU's EN 13130 series are identical adoption (IDT) — the methods are completely identical, so the same sample's test results are valid under both standards. However, reports must be issued separately: a CNAS lab issues a GB-standard report and an EN-standard report (or one report citing both standards).

Difference 4: Regulatory Scope

The EU covers a broader scope — varnishes, coatings, plastics, adhesives, rubber, printing inks and silicone (7 material types). China currently covers only food contact coatings. For sheet metal coating manufacturers, the main practical difference is printing inks: if the product surface has printing (e.g., metal can exterior printing inks), the EU requires those inks to be BPA-free as well, while China's current standard does not cover inks.

Difference 5: Transitional Period

The EU uses a phased approach: 2026.7.20 single-use articles → 2028.1.20 special single-use → 2029.1.20 reusable inventory clearance. China implements uniformly on 2026.9.2 with no phased transition. The EU's phased approach provides more buffer time overall, but the core single-use deadline (2026.7.20) is actually one month earlier than China's implementation date (2026.9.2) — export manufacturers must comply by the EU date.

4. Practical Advice for Export Manufacturers

1. Follow the EU standard — the EU is stricter; meeting it automatically satisfies GB. But reports must be issued separately.

2. Choose fully BPA-free alternative systems — do not use BPF/BPAF to replace BPA (the EU already bans them; GB will likely follow).

3. Submit samples with dual-standard labeling — when sending to a CNAS lab, request the report cite both EN 13130 and GB 31604.5, covering both markets with one report.

4. Reference both regulations in the DoC — in your Declaration of Compliance, cite both EU 2024/3190 and GB 4806.10-2025, covering domestic and international markets with one DoC.

5. Act early — although GB takes effect September 2026, we recommend completing the transition by Q1 2026 to avoid capacity crunch near the deadline.

5. FAQ: GB 4806.10-2025 vs EU 2024/3190

Q1: Which standard is stricter?

A: EU 2024/3190 is stricter in three ways: (1) migration limit is 50× lower (1 μg/kg vs 50 μg/kg); (2) banned substance scope is broader (includes BPS/BPF/BPAF); (3) regulated material types are more comprehensive (7 categories vs 1).

Q2: Are test reports mutually recognized?

A: The test methods are mutually recognized (GB 31604.5 and EN 13130 are identical IDT), but reports must be issued separately. We recommend requesting that the CNAS lab issue a single report citing both standard numbers, covering both markets.

Q3: How many reports do I need for export?

A: Theoretically 1 — submit to a CNAS-accredited lab and request the report cite both EN 13130 and GB 31604.5. In practice, some EU buyers may require reports from EU-based labs (e.g., SGS, Intertek European branches). Confirm with your buyer.

Q4: If we only sell domestically, do we need to follow EU standards?

A: Legally no — comply with GB 4806.10-2025. However, we recommend following EU standards because: (1) GB will likely tighten further to match EU levels; (2) your customers may expand to export markets at any time, and early preparation saves transition time.

Q5: How to control BPA in printing inks?

A: EU 2024/3190 covers printing inks — metal can exterior printing inks must also be BPA-free. China's GB 4806.10-2025 does not currently cover printing inks. Export products must ensure printing ink suppliers also provide BPA-free declarations.

6. Conclusion: Comply with the Stricter Standard, Prepare for Both

GB 4806.10-2025 and EU 2024/3190 share the same direction but differ in strictness, scope and timing. The safe strategy for manufacturers serving both markets is simple: follow the EU standard (stricter, automatic GB coverage), use zero-bisphenol coating systems, and secure dual-standard test reports and DoC — while completing the transition before Q1 2026 to avoid the deadline crunch.

About DINGPRECISION

DINGPRECISION has achieved BPA-free coating mass production with a zirconium pretreatment line, two-spray two-bake coating line, and CNAS/CMA testing capability. We can issue dual-standard test reports (GB 31604.5 and EN 13130) covering both domestic and EU markets.