Food Contact Materials LFGB Compliance

Introduction to Food Contact Materials (FCM)

According to EU Regulation (EC) 1935/2004, various materials and articles that come into direct or indirect contact with food (commonly referred to as Food Contact Materials, FCM for short) must meet their respective regulatory requirements. The objectives of this regulation are:

①　Ensure food contact materials do not endanger human health

②　Safeguard the legitimate rights and interests of consumers

Key Reminders:

①　Different materials (plastics, metals, silicone, etc.) must meet respective requirements such as migration limits

②　FCM qualification requires merchants to submit supporting documents proving the product complies with relevant regulatory requirements

Notes on Qualification Documents

Qualification documents must be a complete test report. The test report should prove that the product has passed the test items required by relevant regulations, including but not limited to the following contents:

①　Basic product information;

②　Basic manufacturer information;

③　Testing standards complying with food contact material regulations;

④　Complete test items with no "Fail" test results;

⑤　Test sample images;

⑥　Mandatory information for test reports such as the signature/seal of the testing laboratory.

⑦　Notes:

⑧　Each SKU's product material must be tested;

⑨　The specific test items in the test report must be consistent with the requirements.

Examples of Test Items and Standards

Paper and Paperboard

The following test items can be conducted in accordance with regulations LFGB, AP (2002) 1, CM/Res (2020) 9:

①　Extractable Heavy metals (Pb, Cd, Hg, Cr(VI), Al)

②　Extractable Heavy metals (Pb, Cd, Hg)

③　Migration of Fluorescent Whitening Agent in water, 3% acetic acid, alkaline salt solution or olive oil

④　The Transfer of Antimicrobial constituents (or Preserving effect)

⑤　Colorfastness in water, 3% acetic acid, alkaline salt solution or olive oil

⑥　Pentachlorophenol content

⑦　Extractable Formaldehyde

⑧　Specific Migration of 4,4'-BIS(dimethylamino)benzophenone (Michler's ketone)

⑨　Specific Migration of benzophenone, 2-methylbenzophenone, 3-methylbenzophenone and 4-methylbenzophenone

⑩　Extractable primary aromatic amine

⑪　Organoleptic Inertia

Glass, Ceramics, Crystal, Stone

The following test items can be conducted in accordance with regulations 84/500/EEC and its Amendment 2005/31/EC, DGCCRF:

①　Leachable Lead, Cadmium, Cobalt, Aluminium and Arsenic

②　Lip and rim region: Leachable Lead, Cadmium

Metals

The following test items can be conducted in accordance with regulation CM/Res (2013) 9:

①　Sensory test - taste and odour to the integrate product

②　Extractable Heavy metals (24 Heavy metals)

③　Overall Migration

Wood, Bamboo, Rattan

The following test items can be conducted in accordance with regulations AP (2004) 2, DGCCRF:

①　Pentachlorophenol content (PCP)

②　Specific Migration of Formaldehyde

Silicone, Organosilicon

The following test items can be conducted in accordance with regulations CM/Res (2020) 9, AfPS and ProdSG, LFGB, AP (2004) 5:

①　Sensory test - taste and odour to the integrate product

②　PAH content

③　Volatile Organic Matter

④　Peroxide value

⑤　Visible Color Migration

⑥　Overall Migration

⑦　Total Platinum

Rubber

The following test items can be conducted in accordance with regulation AP (2004) 4:

①　Overall Migration

②　N-nitrosamines and N-nitrosatable Substances

③　Specific Migration of N-nitrosamine & N-nitrosatable substances (water, 3% acetic acid or 10% ethanol)

④　PAH content

⑤　Specific Migration of Primary Aromatic amine (PAA)

General Requirements for Plastics, Resins

The following test items can be conducted in accordance with regulations AP (89) 1, 1935/2004/EC, No.10/2011 and its Amendments:

①　Sensory test - taste and odour to the integrate product

②　Overall Migration

③　Specific Migration of 19 Heavy metals in 3% acetic acid

④　PAH content

⑤　Visible Color Migration

Polyphenylsulfone (PPSU)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Total BPA content (applicable only to products for children under 3 years old)

Polycarbonate (PC), Polystyrene (PS)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Total BPA content (applicable only to products for children under 3 years old)

③　Specific Migration of BPA in 3% acetic acid

Polypropylene (PP), Polyethylene (PE)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Total BPA content (applicable only to products for children under 3 years old)

③　Specific Migration of Octene in olive oil

④　Specific Migration of Hexene in olive oil

Polyethylene Terephthalate (PET)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Specific Migration of Terephthalic Acid in 3% acetic acid

③　Specific Migration of Ethylene glycol in 3% acetic acid

④　Specific Migration of Acetaldehyde in 3% acetic acid

⑤　Total BPA content (applicable only to products for children under 3 years old)

⑥　Specific Migration of Primary Aromatic amine (PAA) in 3% acetic acid

Polyvinyl Chloride (PVC), Vinyl

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Content of Vinyl chloride monomer (VCM)

③　Organotin content

④　Specific Migration of Vinyl chloride monomer

⑤　Phthalates

⑥　Specific Migration Phthalates

Acrylonitrile Butadiene Styrene (ABS)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011, No.10/2011 and its Amendments:

①　General requirements for plastics

②　Residual 1,3-Butadiene

③　Specific Migration of Acrylonitrile in 3% acetic acid

④　Total BPA content (applicable only to products for children under 3 years old)

⑤　Specific Migration of Primary Aromatic amine (PAA) in 3% acetic acid

⑥　Specific Migration of Acrylonitrile in 10%, 20% or 50% ethanol

⑦　Specific Migration of 1,3-butadiene

Tritan

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Specific Migration of TMCD in 3% acetic acid

③　Total BPA content (applicable only to products for children under 3 years old)

④　Specific Migration of Primary Aromatic amine (PAA) in 3% acetic acid

Nylon (Polyamide PA)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011, No.10/2011 and its Amendments:

①　General requirements for plastics

②　Specific Migration of Caprolactam

③　Specific Migration of Hexamethylenediamine

④　Specific Migration of Primary Aromatic amine (PAA) in 3% acetic acid

Enamel

The following test items can be conducted in accordance with regulation 1935/2004/EC:

①　Specific Migration of Heavy Metals in 3% acetic acid (Al/Ag/As/Ba/Cd/Co/Cr/Cu/Li/Mn/Mo/Ni/Pb/Sb/Zn)

②　Sensory test - taste and odour to the integrate product

Melamine

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Specific Migration of Primary Aromatic amine (PAA)

③　Specific Migration of Formaldehyde

④　Specific Migration of Melamine

⑤　Total BPA content (applicable only to products for children under 3 years old)

Polyoxymethylene (POM)

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

①　General requirements for plastics

②　Specific Migration of Formaldehyde

BPA-Free

The following test items can be conducted in accordance with regulations 1935/2004/EC, No. 10/2011:

· Total BPA content (applicable only to products for children under 3 years old)

Phthalate-Free

Test item reference: Phthalates

Nitrosamine-Free

Test item reference: N-Nitrosamines

Other Materials

If the product does not belong to any of the above materials, it must be tested for all test items in accordance with all the above test standards.