Tableware, kitchen appliances, food packaging, bottles, cutting boards, coffee equipment, straws, storage containers — anything that touches food carries a separate layer of regulation that most importers discover at the border. This article is for companies importing commercial batches of food-contact goods and explains which rules apply, what testing actually proves, and what documents to demand before production starts.
The rule set, by market
- EU — framework. Regulation (EC) No 1935/2004 sets the principle: materials must not endanger health, or change the taste, smell, colour or composition of the food.
- EU — plastics. Regulation (EU) No 10/2011 governs plastic materials, with an overall migration limit of 60 mg/kg (or 10 mg/dm²) and specific migration limits per substance, plus a positive list of authorised substances.
- EU — good manufacturing practice. Regulation (EC) No 2023/2006 requires GMP throughout the chain.
- Germany — LFGB. The German Food and Feed Code, frequently requested as a stricter national reference alongside the EU rules; for non-plastic materials, the BfR recommendations do much of the work the EU has not harmonised.
- USA — FDA. 21 CFR governs food-contact substances. Note that "FDA approved" is a misnomer for most articles: what exists is compliance with the applicable CFR sections, or a food-contact notification for a substance.
- China — GB 4806 series. The national standards for food-contact materials, covering general safety, plastics, paper, metals, coatings and rubber as separate parts.
Ukraine and other EU-model markets align on the European framework; the general logic of matching documents to markets is in which documents you need to sell goods imported from China.
GB 4806 is not EU compliance
A Chinese factory will usually hold GB 4806 test reports, because that is what it needs to sell domestically. Those reports demonstrate compliance with Chinese requirements. They are useful evidence of capability, they are not evidence of EU or US compliance, and a supplier presenting them as interchangeable is either mistaken or hoping you are.
Specify the target standard in writing at order stage, exactly as you would a material grade — see the technical spec sheet for a Chinese factory.
Migration testing must match how the product is used
This is the part that catches experienced importers. Migration testing is not a single generic test. It is performed with food simulants chosen to represent the food type — aqueous, acidic, alcoholic, fatty, dry — under time and temperature conditions matching intended use.
A cup tested for cold water is not tested for hot coffee. A container tested at room temperature is not tested for a microwave or a dishwasher. A lid tested for aqueous food is not tested for oil. If your product will be marketed for hot, fatty or repeated-use conditions, the report has to say so, and the specified conditions must be at least as severe as the real ones.
So the correct instruction to a supplier is never "get a food-contact report." It is: test this material, against this regulation, with this simulant, at this temperature, for this duration, for repeated use.
What a real Declaration of Compliance contains
For EU plastics, the deliverable is a Declaration of Compliance (DoC) — not a certificate — issued down the supply chain. A usable one names:
- The identity and address of the business issuing it
- The material or article, and the materials it is made from
- The regulations it complies with, including 1935/2004 and 10/2011 where applicable
- Any substances with specific migration limits or restrictions, and dual-use additives
- The conditions of use it covers: food types, temperature, contact duration, repeated use
- Confirmation that the requirements have been verified by testing, with the supporting reports referenced
A DoC that omits the conditions of use is not a usable DoC, because those conditions are the whole point.
Material-specific traps
- Melamine and composite tableware. Composites containing plant fibres — bamboo-melamine being the best known — have repeatedly been refused in the EU because the additive is not on the authorised list. "Eco bamboo" tableware is one of the most commonly rejected categories at EU borders.
- Coatings and non-stick. The coating is the food-contact material, not the metal underneath. It needs its own evidence.
- Recycled plastics. Recycled content in food-contact plastics is separately regulated and cannot be assumed compliant.
- Printing inks and adhesives on packaging migrate through the substrate; the printed side is part of the assessment.
- Coloured plastics. Pigments and masterbatch are where heavy metals enter an otherwise compliant polymer.
- Silicone and rubber are not harmonised across the EU in the way plastics are, which pushes reliance onto national rules such as the German BfR recommendations.
What to request from the factory
- The Declaration of Compliance for the finished article, and for the raw materials from their suppliers
- Migration test reports naming the simulants, temperatures, durations and repeat-use assumptions
- The laboratory's identity and accreditation number — verifiable, as described in how to check whether a Chinese certificate is genuine
- Confirmation of which regulation was tested against — EU, LFGB, FDA or GB — in writing
- A no-substitution undertaking covering resin grade, masterbatch, coating and any additive, as part of the contract with the factory
- Labelling requirements: the glass-and-fork symbol or an equivalent statement, plus use conditions on the product or packaging — a decision that belongs in packaging development
Timing and cost
Migration testing is priced per material and per simulant-condition combination, so the cost scales with how many materials your product contains and how many use scenarios you claim. A single-material item tested for one condition is inexpensive; a coffee machine with a coated boiler, silicone seals, a printed housing and a plastic reservoir is several tests, and the schedule reflects that. Two to six weeks is typical, longer where repeated-use testing is required.
Start it before mass production. A migration failure discovered after the batch exists means the batch cannot be sold — and unlike a cosmetic defect, there is no rework that fixes a material.
Food contact is the one compliance area where the product can be perfectly made, perfectly safe-looking and still illegal to sell — because compliance lives in the material and the conditions of use, not in the workmanship.
Handling food-contact compliance before production
We specify the target regulation and the exact test conditions in the factory documentation, check existing reports against the actual product and its intended use, verify laboratories against their accreditation scope, and arrange testing on samples pulled from production rather than supplied by the factory. Seven years, 3,500+ deliveries, 340+ verified suppliers — real projects in our case studies.
Start with product sourcing or quality inspection.
