Product compliance · Migration + DoC + 1935/2004

Food-contact materials

Migration testing, declarations of compliance and the EU framework rules for plastics and other materials.

Key facts

EU routeFramework Regulation 1935/2004; plastics under 10/2011
US routeFDA food-contact notification or listing
UK routeRetained EU food-contact rules and declarations
Core testsOverall and specific migration; sensorial testing
Key documentsDeclaration of compliance, migration reports, MSDS
RecurringSupplier declarations and reformulation checks
Typical one-off budgetUSD 400–2,500 per material and use case
Last verified2026-10-17

The use case decides the test

A food-contact material is assessed against the food type, the temperature and the contact time it is designed for. A cold-drink bottle and an oven tray made from the same polymer can need different migration testing and different declarations. The file has to state the intended use, not just the material.

Recycled content and multi-layer structures add questions about the source and the functional barrier. A supplier declaration that only names the resin is not enough for a finished article.

The declaration travels with the goods

In the EU, a declaration of compliance accompanies food-contact materials, and the business customer is entitled to the supporting information. The declaration is not a one-time marketing document; it has to match the article, the materials and the intended use.

The US route depends on the substance: some materials are covered by prior sanction or a food-contact notification, others need a notification. The same article can therefore be simple in one market and slow in another.

Frequently asked questions

Is a migration test valid for every food type?

No. The test conditions depend on the food category, temperature and contact time. The declaration should state which conditions it covers.

Do I need a new declaration when I change suppliers?

Yes, if the material or the process changes. The declaration has to describe the article actually being supplied.

Does food-contact compliance apply to packaging only?

It applies to articles intended to contact food, including packaging, tableware, storage containers and processing equipment.

Tell me when the rules change

De minimis thresholds, import tax rates and marketplace fee schedules move more often than most price lists. Leave an address and we will send a short note when one of the tracked markets changes.

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