Food contact materials obligations attach to the material, the food it touches, and the contact time and temperature, not to the product name. Two identical-looking items can carry different requirements if one is used with hot or acidic food. Define the intended use first, then ask for a document pack that matches it and your destination market.
Requirements follow the use, not the product
The most common mistake in food-contact compliance is asking whether a product is food safe. The question has no general answer. Regulators assess a material in the context of what it touches, for how long, and at what temperature.
A stainless steel tray used to serve dry biscuits at room temperature is a low-demand application. The same tray used for hot, acidic sauce presents a different case, because heat and acidity both increase migration from the material into the food. Same product, same material, different obligations.
This is why a supplier declaration that says food grade, with nothing else on it, is close to worthless. It does not say which regulation, which material, which food type or which conditions. Ask instead for a declaration that names the framework, the material, the intended contact conditions and the test evidence behind it.
What documents do I actually need to import kitchenware?
A pack rather than a certificate. For most kitchenware that means: a Declaration of Conformity naming the regulation and the conditions of use, migration or composition test reports from an accredited laboratory covering each material in the contact path, evidence of manufacture under good manufacturing practice, and batch traceability linking a shipped unit back to the tested material. One generic certificate covering a finished product is not the same thing and rarely survives a retailer audit.
What each market expects
The four markets this site is written for take broadly similar approaches with meaningfully different paperwork. The table below is a planning summary, not legal advice, and requirements change.
The European Union is the most document-heavy of the four. The European Commission states that "all food contact materials must comply with Regulation (EC) No 1935/2004" when placed on the European market, and that in addition "all FCM must be manufactured in accordance with Good Manufacturing Practices (GMP, Commission Regulation (EC) No 2023/2006), and specific Union legislation on certain materials, including on plastic and ceramics".
Great Britain retained an equivalent framework after leaving the EU, so the substance is similar but the declaration should reference the retained legislation rather than the EU instrument. A declaration citing only the EU regulation is a common and avoidable defect in a GB document pack.
The United States works through the FDA framework in 21 CFR. The relevant question is usually whether the material and any coatings are permitted for the intended use, and the assessment is substance by substance. As the FDA puts it, "the overall regulatory status of a food contact material is dictated by the regulatory status of each individual substance that comprises the article". For plain metals this often resolves quickly; for plastics, coatings and colourants it requires more care.
Australia and New Zealand work through the Food Standards Code, which references material standards for articles in contact with food. Canada operates through the Food and Drugs Act, and buyers are often asked for a letter of no objection or a supplier declaration supported by test evidence. Our market compliance pages set out what we can supply for each destination.
The number people quote wrongly
For plastic components there is a hard figure, and it is worth getting right because it is widely misquoted. Article 12 of Regulation (EU) No 10/2011 sets the overall migration limit: "Plastic materials and articles shall not transfer their constituents to food simulants in quantities exceeding 10 milligrams of total constituents released per dm2 of food contact surface (mg/dm2)."
You will frequently see this written as "10 mg/dm² or 60 mg/kg", as though the two were interchangeable ways of saying the same limit. They are not. In the same article, the 60 mg/kg figure is a derogation applying to materials intended for contact with food for infants and young children. The recitals explain where the number comes from: 10 mg per dm² happens to work out at 60 mg per kg for a cubic package holding one kilogram of food, but that arithmetic is not the general limit.
The practical point for a buyer: if a test report or a declaration quotes 60 mg/kg for an ordinary adult-use kitchen product, ask which provision it is relying on. It may be correct, it may be a conversion, or it may indicate the report was written to the wrong basis.
Materials that need the most attention
Not every component carries equal risk. Concentrate documentation effort where migration is most plausible.
Swipe or scroll the table to compare all columns.
| Material | Typical concern |
|---|---|
| Stainless steel | Generally well understood. Confirm the grade suits the food type; migration of nickel and chromium is assessed in some frameworks. |
| Plastics and silicone | The highest-scrutiny category. Additives, plasticisers and colourants all migrate. Expect migration testing. |
| Coatings and non-stick | The coating is a separate material from the substrate and needs its own evidence. |
| Painted or printed surfaces | Decoration near a food-contact surface may require its own assessment, especially inks and lacquers. |
| Wood and bamboo | Porosity, treatment chemicals and cleaning behaviour all matter; requirements vary widely by market. |
| Adhesives and seals | Easily overlooked because they are hidden, but they sit in the contact path. |
For a mixed-material product, ask for documentation covering every material in the contact path, not only the visible one. A steel scoop with a plastic handle and a silicone seal is three materials. Where grade drives corrosion performance rather than migration, our 304 vs 430 comparison covers which grade belongs where.
Do I need to re-test if I change the handle material or the colour?
Usually yes for the changed component, and this catches people out on a second order. Evidence attaches to a material and a formulation, not to a product name. A new colourant is a new formulation. A handle moulded from a different resin is a different material. Changing factory can also invalidate a report, because the evidence was generated for that manufacturer's material and process. Ask before the change, not after the artwork is printed.
What to ask the factory for
Frame the request around your intended use so the supplier can produce evidence that actually covers it.
- State the food type, contact temperature and contact duration in your brief. Aqueous, acidic, fatty and dry foods are assessed differently.
- Ask for a Declaration of Conformity naming the specific regulation, the material and the conditions of use it covers.
- Request test reports from an accredited laboratory, and check the report references your material and configuration rather than a generic sample.
- Check the report date. Some buyers require testing within a defined period, and an old report may not satisfy a retailer even if it satisfies a regulator.
- Ask who holds the technical file and whether you will receive a copy.
- For a repeat order, confirm whether the documentation still applies or needs refreshing.
Who issues the Declaration of Conformity, the factory or the lab?
The business responsible for the material issues the declaration; the laboratory issues the test report that supports it. A lab will not declare conformity on a factory's behalf, and a factory cannot substitute a test report for a declaration. You should expect both, and they should reference each other.
Labelling and traceability
Documentation is only half the obligation. Several markets also expect the product or its packaging to carry specific marks, and expect you to be able to trace a unit back to a production batch if a problem emerges.
The glass-and-fork symbol is the recognised European indication that an article is intended for food contact. It is not required on every item: where the intended use is obvious from the product itself, a knife or a saucepan, the symbol can generally be omitted. Where the use is not obvious, or the article could be mistaken for something else, the symbol or equivalent wording is expected.
Traceability means being able to identify which production batch a unit came from. In practice that is a batch or date code applied to the product or the carton, recorded against the production run and the material certificates for that run. It sounds bureaucratic until a customer reports a problem, at which point it is the difference between withdrawing one batch and withdrawing everything you have ever sold.
Agree the code format, where it is applied and who records it before production starts. A code stamped on a carton that is discarded at the shelf gives you nothing once the product is in a home. Our documents page sets out what we record against each run.
Building it into the project schedule
How long does food-contact testing take?
A migration test at an accredited laboratory commonly takes two to four weeks once a sample is available, and the sample has to be representative of production rather than a hand-made prototype. Testing is frequently discovered late, which is why it becomes a schedule problem rather than a cost problem.
That sequencing catches people out. You cannot test a representative sample until tooling and material are settled, and you may not want to commit to tooling until you are confident the material will pass. The practical resolution is to test early on a pre-production sample for indication, then confirm on production material, and to budget for both. The sample approval guide explains which sample stage is representative enough to test.
Where a product will carry a food-contact symbol or a specific claim on its packaging, check the artwork against the evidence before printing. A claim printed on ten thousand cartons that the documentation does not support is an expensive correction, and one of the few compliance errors that is genuinely impossible to fix quietly.
Your checklist
- Intended food type, temperature and contact duration defined
- Destination markets listed, with the framework named for each
- Every material in the contact path identified, including seals and coatings
- Declaration of Conformity requested naming regulation, material and conditions
- Test reports from an accredited laboratory, referencing your configuration
- Migration basis checked: 10 mg/dm² general, 60 mg/kg only where the derogation applies
- GB declarations referencing retained legislation, not the EU instrument
- Report dates checked against retailer requirements
- Re-testing agreed for any change of material, colourant or factory
- Responsibility for holding the technical file agreed
- Batch coding format and placement agreed before production
- Testing time built into the project schedule
- Packaging claims checked against the evidence before printing