LFGB certification for kitchenware: what it really is

The correction that saves you money

What is LFGB certification, and does it exist?

LFGB stands for the Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch, the German Food, Consumer Articles and Feed Act. It is a law, not a certification scheme. There is no body that awards an LFGB certificate, no register of certified products, and no logo that means certified to LFGB.

The German Federal Institute for Risk Assessment (BfR) says this directly. In its FAQ on food contact materials, BfR writes: "The BfR does not issue certificates of this kind. Testing and determination of compliance with the BfR recommendations can be performed by testing institutes with competence in the monitoring of food contact materials."

So when a factory or an agent offers you LFGB certification, what exists in the file is a test report. A laboratory took a sample of one material, ran defined tests, and issued a report saying the results met, or did not meet, the relevant criteria. That report is genuinely useful. It is simply not a certificate, and treating it as one causes buyers to accept a single sheet of paper for a product made of three different materials.

This matters commercially because the word certification implies coverage of a finished product. A test report covers a material and a set of conditions. Our food contact kitchenware guide is the hub for this topic and sets out how the different pieces of evidence fit together across markets.

Where the BfR recommendations fit

German food contact requirements are not only the LFGB text. Alongside the law sit the BfR recommendations, which is where most of the practical detail for plastics and silicones lives.

BfR explains the status of these documents carefully: "The BfR recommendations on food contact materials are not legal norms. However, they reflect the current state of science and technology for the conditions under which consumer products of high polymer materials meet the requirements of § 31.1 of the Food, Consumer Articles and Feed Act (LFGB) and Article 3.1.a of Regulation (EC) No 1935/2004 in terms of their non-hazardousness for human health."

Read that carefully. A BfR recommendation is not itself binding, but it is the accepted route to showing that a high polymer material meets LFGB section 31. That is why a silicone test report will usually reference a BfR recommendation rather than the LFGB text alone.

BfR also explains why the recommendations exist at all: "The BfR publishes recommendations for areas which are not yet legally regulated. This applies to high polymers, such as plastics, silicones, natural and synthetic rubber as well as papers, cartons and cardboards." In other words they fill gaps where harmonised European rules do not reach. That is exactly the gap silicone spatula edges and wooden or paperboard components fall into.

What is the difference between LFGB section 30 and section 31?

Buyers see both quoted on reports. Section 30 is the prohibition on placing on the market consumer articles that are capable of harming health. Section 31 is the provision on transfer of substances from a material to food, which is the migration principle, and it is the section BfR cites in the passage above. A report referencing section 31 is dealing with what comes out of the material into food. A report referencing section 30 is dealing with the broader safety of the article.

Both are provisions of German law, so both are enforced in Germany rather than certified. BfR notes that "The enforcement of provisions laid down in the German Food, Consumer Articles and Feed Act (LFGB) is the responsibility of the German federal states ('Laender')." Enforcement sits with state authorities who sample products on the market. There is no gatekeeper approving your product before it ships.

Is LFGB mandatory in Germany?

The law is mandatory. Compliance with it is not optional for anything sold in Germany. Testing is a different question: no authority requires you to hold a test report before you sell, but if a state authority samples your product and it fails, you are in breach of the law and the report is what you would have relied on.

In practice, German and Austrian retail buyers ask for LFGB test reports as a condition of purchase, and many EU-wide buyers do too because the German requirements are well defined. So it behaves like a commercial requirement even though it is not a pre-market approval. Our overview of European Union requirements covers how this sits alongside the rest of the EU picture.

LFGB vs FDA: two different approaches

Is LFGB stricter than FDA for silicone?

The honest answer is that they are not directly comparable, and buyers who ask which is stricter are usually asking the wrong question. The two systems are built differently.

The US approach for a rubber article intended for repeated use, which covers silicone kitchen tools, is a numeric extractives limit that depends on the food type. 21 CFR 177.2600 sets, for aqueous food contact, "total extractives not to exceed 20 milligrams per square inch during the first 7 hours of extraction, nor to exceed 1 milligram per square inch during the succeeding 2 hours". For fatty food contact the same section sets "total extractives not to exceed 175 milligrams per square inch during the first 7 hours of extraction, nor to exceed 4 milligrams per square inch during the succeeding 2 hours". That is a defined pass or fail number against a defined simulant and time.

The German route works from the BfR recommendations, which as BfR itself says reflect the state of science and technology for meeting LFGB section 31, rather than from a single US-style extractives number for the article. The list of substances permitted in the formulation and the sensory assessment of the finished part carry more weight. This is why the same silicone can pass one and be questioned under the other, and why a buyer who needs both markets should plan both tests rather than assume one covers the other.

One caveat you should hold onto: 21 CFR 177.2600 is a United States rule. It says nothing about the UK, Australia or Canada, which each handle food contact differently. Do not let a supplier present an FDA test report as a global answer.

Do I need both FDA and LFGB testing?

If you sell into both the US and Germany, yes, in most cases. They are separate legal systems with separate evidence. A German retailer will not accept an FDA report in place of an LFGB report, and a US importer has no use for a BfR reference.

If you sell into only one of them, testing for the other is money spent on reassurance rather than compliance. Some brands still do it because it reads well on a product page, which is a marketing decision rather than a regulatory one. We will quote either or both, and we will tell you when we think you are buying paperwork you do not need.

For the UK, Australia and Canada the position depends on your own market and your own importer, and it is not something a Chinese factory should answer for you with confidence. Ask your local compliance advisor or your retailer's technical team what evidence they will accept. Our summary of food contact materials sets out what we can and cannot speak to.

A real test plan for one mixed-material SKU

Here is where most guidance stops and most projects get into trouble. A single kitchen tool is rarely a single material, and an LFGB test report covers a material, not a product.

Take a spatula we build regularly: a 304 stainless steel core, a moulded silicone edge, and a polypropylene handle with a small TPE grip insert. Four materials on one SKU. Each needs its own evidence, and the scope of each report is different.

Swipe or scroll the table to compare all columns.

Two things in that table catch buyers out. First, the colourant is a separate line. Changing a spatula from grey to red changes the masterbatch, which changes the formulation, which can invalidate a silicone report that was run on the grey compound. Second, incidental contact is still contact. A handle that meets food when the tool rests in a pan is in scope even if it never sits in the food.

Which tests apply to a stainless steel food-contact part?

Stainless steel sits outside the BfR recommendations entirely. BfR is explicit that its recommendations cover high polymers, plastics, silicones, rubber, paper and board. Metal is a different route, and what a laboratory looks at for a stainless part is the release of metals from the alloy under defined conditions rather than a polymer migration test.

The practical consequence is that the grade of the steel matters to the result. A part made in 430 behaves differently from one made in 304, and our guide to 304 vs 430 stainless steel explains why the alloy choice is a specification decision, not a cost decision alone. Get the mill certificate for the lot you are actually running, and make sure the material that was tested is the material in production.

How does KOVA sequence this against tooling?

This is the part that saves money, and it comes from doing it badly once. We plan material testing against the tooling calendar rather than after it.

The order we use is: lock the material specification per part before steel is cut, run testing on production-intent material from the actual compound and masterbatch, then approve the sample. If testing comes after tooling, a failed silicone compound means a new compound, which can mean a different shrinkage rate, which can mean modifying the mould. A failed test at that point costs tooling money, not just laboratory money.

We also test the compound, not the shade, where a range shares one base. If a buyer is launching four colours of the same spatula, we plan one full test on the base compound and a narrower pigment assessment per colour, rather than four full reports. That is a judgement call we agree with the buyer in writing before we book the tests, because their retailer may insist on more. Our sample approval process shows where the testing checkpoints sit in the wider timeline.

Reading and using the report

How long is an LFGB test report valid, and does it transfer if I change factory?

A test report has no expiry date printed on it because it is a record of a test on a sample on a date, not a licence with a term. What ages is its relevance. The report describes a material as it was when it was tested. If the compound, the supplier, the masterbatch or the process changes, the report no longer describes what you are shipping.

Most retail buyers set their own refresh interval, commonly one to three years, and that is their policy rather than a legal rule. Ask your buyer what they apply rather than assuming.

On transferring between factories, the answer is usually no, and this catches out brands moving production. The report belongs to whoever commissioned it and describes that factory's material from that factory's supplier. A new factory buying silicone from a different compounder is a different material, even if the drawing is identical. Plan for retesting in a factory transfer budget. If you commission the testing in your own name rather than the factory's, you at least own the document, which is worth arranging at the start.

Can I put the glass-and-fork symbol on my packaging?

The glass-and-fork symbol indicates that an article is intended to come into contact with food. It is a declaration of intended use. It is not a certification mark, it does not mean a laboratory approved the item, and it carries no reference to LFGB.

What underpins it is your evidence that the material is suitable for the use you are declaring. Applying the symbol to a product with no test behind it is a declaration you cannot support. This is also a labelling decision that varies with your destination market, so confirm the artwork with your own importer rather than with us. We will print what you approve on the artwork.

What should the report actually say?

Read past the pass line. A report is only as good as its scope, and the scope is where a weak one falls apart.

• The part name and the material, specific enough to match your bill of materials.
• The laboratory's name and accreditation, and a report number you can verify with them.
• The test conditions: simulant, temperature, duration, and repeated-use assumptions.
• The provision tested against, for example the relevant BfR recommendation and LFGB section 31.
• The sample description, including colour, and whether it was production material or a hand sample.
• The date, and the client who commissioned it.

A report that names a generic material with no colour, no conditions and no client is close to worthless in an audit. We keep the full document set per SKU rather than a summary sheet, and our page on compliance documents lists what travels with an order.

Your checklist

• Asked for an LFGB test report, not an LFGB certificate
• One report per material, not one report per product
• Colourant and masterbatch treated as a separate line in the test plan
• Report scope checked: simulant, temperature, duration, sample colour
• BfR recommendation and LFGB section referenced on polymer reports
• Stainless parts covered by metals release testing plus a mill certificate
• Testing booked on production-intent material before tooling is cut
• Testing commissioned in your own name where you want to own the document
• Separate FDA evidence planned if you also sell into the US
• Required evidence confirmed with your own importer or retailer
• Retest budgeted if you change factory, compound or supplier