LFGB Test Requirements for Food Contact Materials

For enterprises planning to sell food contact materials in Germany, LFGB certification is an insurmountable compliance threshold. Many enterprises have had their products seized by German customs or removed from shelves due to neglecting this certification, which not only causes econoMIC losses but also damages the brand's overseas reputation. As a core requirement of Germany's Lebensmittel- und Futtermittelgesetzbuch (LFGB) (Food, Commodity and Feed Code), lfgb certification, with its stringent testing standards, has become a key line of defense for safeguarding consumer health. This article will comprehensively break down the key LFGB compliance points from certification definition, applicable products and testing items to certification process, helping you smoothly access the high-end markets of Germany and the European Union.

What is LFGB Certification and Why is it Mandatory?

LFGB certification is not a single testing item, but a mandatory safety regULation formulated by Germany for all materials and products in contact with food. It is also one of the most recognized and stringent food contact safety standards within the EU. Its core objective is to ensure, through scientific testing, that products do not release harmful substances (such as heavy metals and toxic chemicals) to contaminate food during contact (e.g., holding, cooking, packaging), thereby protecting consumer health.

Three Core Points of LFGB Certification

1. Mandatory legal effect: All food contact products entering the German market, regardless of being produced in China or other countries, must comply with LFGB requirements. Products that fail to meet the standards will be banned from sale and may even face penalties such as fines and recalls.

2. Wide scope of application: It covers all materials and products that may come into contact with food, including plastics, silica gel, metals, ceramics, glass, paper packaging and coatings. Everything from straws and bottle caps to cookware and coffee machine inner liners must be compliant.

3. Clear certification marking: After passing the LFGB test, products can be marked with "LFGB compliant" or "LFGB approved". This marking is an important basis for German consumers to identify safe products and can significantly enhance the market trust of products.

Which Products Require LFGB Certification?

Both finished products and raw materials require LFGB certification if they may come into direct or indirect contact with food (including liquids, solids and semi-solids such as beverages, snacks and sauces) during use. They can be specifically divided into four categories:

1. Kitchen Utensils: Essential for Daily Cooking and Dining

These products have the highest frequency of food contact and are the key focus of LFGB testing, including:

①　Tableware: Metal knives and forks, ceramic bowls and plates, wooden chopsticks, plastic spoons, etc.

②　Cooking appliances: Non-stick pans (coating safety to be tested), stainless steel pots, silica gel steamer mats, baking molds (e.g., cake molds, cookie molds).

③　Auxiliary tools: Plastic cutting boards, silica gel spatulas, metal egg beaters, food-grade scissors.

2. Food Packaging: Critical for Storage and Transportation

Packaging materials must be strictly compliant as harmful substance release will directly contaminate food, including:

①　Containers: Plastic fresh-keeping boxes, glass storage jars, silica gel sealed bags.

②　Disposable packaging: Plastic food bags, paper lunch boxes, aluminum foil packaging.

③　Beverage-related: Plastic beverage bottles, glass water cups, straws, bottle caps (especially inner stoppers in direct contact with beverages).

3. Small Home Appliance Contact Components: Compliance RequiRED for Indirect Contact

Components of small home appliances that come into contact with food, though not purchased separately by consumers, must still meet LFGB requirements, including:

①　Heating/processing components: Coffee machine brewing chambers, juicer augers, rice cooker inner liners, electric kettle inner liners.

②　Auxiliary components: Food processor blades (metal parts), yogurt maker inner liners, bread machine baking pan coatings.

4. Special Contact Materials: Covering Niche but High-Frequency Scenarios

These products, despite having specific usage scenarios, also require certification due to direct food contact, including:

①　Silica gel products: Food-grade silica gel ice cube trays, silica gel baking gloves, silica gel baby bottle accessories.

②　Coatings/resins: Canned food inner wall coatings (to prevent metal leaching), melamine resin tableware (e.g., melamine bowls).

③　Paper products: Food packaging paper (e.g., cake cups, candy wrappers), disposable paper cup inner wall coatings.

What are the LFGB Certification Testing Items?

LFGB certification testing items are centered on "no migration of harmful substances and no food contamination". The testing focus varies slightly for different materials (e.g., plastics, ceramics, metals), but the core can be summarized into six categories:

1. Sensory Test: The Most Intuitive Safety Screening

As a basic LFGB testing item, it simulates actual usage scenarios (e.g., holding water, oil and acidic food with the product) to detect whether the product causes changes in the taste, odor or color of food. For example: whether water has a silica gel odor after being held in a silica gel mold, and whether vinegar changes color after being held in a ceramic bowl. Any abnormality results in an immediate failure judgment.

2. Heavy Metal Migration Test: Eliminating Toxic Metal Leaching

For materials such as metals, ceramics and glass, it tests the leaching amount of heavy metals including lead, cadmium, mercury and chromium. Strict and clear limits are set for different materials, for example:

①　Ceramic products (especially colored glazed ones): Lead migration ≤ 0.8mg/dm², cadmium migration ≤ 0.07mg/dm².

②　Metal products (e.g., stainless steel pots): Chromium migration ≤ 0.05mg/dm², nickel migration ≤ 0.1mg/dm².

3. Overall Migration Test: Assessing Total Migration Risk

It tests the total amount of all migratable substances in materials, simulating different food environments (water-based food, acidic food such as vinegar, alcoholic food such as cooking wine, oily food such as edible oil) to measure substance migration under different temperatures and time periods. For example: whether a large amount of chemical substances migrate from a plastic fresh-keeping box to oily food after microwave heating. The total migration limit is ≤ 60mg/kg (slightly different for different materials).

4. Special High-Risk Substance testing: Targeted Hidden Hazard Investigation

It conducts special testing for common high-risk substances in different materials, including:

①　Primary Aromatic Amines (PAA): Commonly found in colored plastic and rubber products, which may harm health with long-term contact and thus require strict restrictions.

②　BISphenol A (BPA): Mostly found in plastic baby bottles and food packaging films, which may affect the endocrine system. LFGB requires a migration limit of ≤ 0.05mg/kg.

③　Formaldehyde: A key testing item for melamine resin tableware (melamine bowls) to avoid formaldehyde release at high temperatures.

④　Nitrosamines: Required for rubber products (e.g., silica gel sealing rings, rubber pacifiers) to prevent migration into food.

5. Plastic Product Special Testing: Focusing on Plastic-Specific Risks

Due to their complex composition (e.g., containing plasticizers and additives), plastics require additional special testing:

①　Phthalates (plasticizers): Commonly found in soft plastic products (e.g., plastic straws, silica gel toys), and LFGB prohibits their use in children's food contact products.

②　Volatile Organic Compounds (VOC): Testing whether plastics release volatile harmful gases at high temperatures.

③　Peroxide residue: A mandatory testing item for silica gel products (e.g., silica gel steamer mats) to avoid food contamination by residual substances.

6. Microbiological Test: Ensuring Sanitary Safety

Mainly for reusable food contact products (e.g., tableware, water cups) and infant products (e.g., silica gel baby bottles), it tests the microbial content on the product surface (e.g., total bacterial count, Escherichia coli) to ensure that products meet sanitary standards ex-factory and avoid food safety issues caused by microbial contamination.

LFGB Certification Acquisition Process

The LFGB certification process is clear, and enterprises can complete compliance efficiently by following the steps, which are specifically divided into five phases:

1. Product Classification and Scheme Formulation

First, clarify the product's material type (e.g., plastic, ceramic, metal) and usage scenario (e.g., holding acidic food, heating use). The testing institution formulates a personalized testing scheme based on LFGB standards and product characteristics, specifying the required testing items (e.g., heavy metal migration + sensory test for ceramic bowls, plasticizer + overall migration test for plastic straws).

2. Sample Preparation and Submission

Enterprises need to provide representative samples: for mass-produced products, random sampling is required (avoid deliberately preparing "qualified samples"); for components (e.g., rice cooker inner liners), complete assemblies must be provided. The number of samples depends on the testing items, usually 3-5 pieces (e.g., 5 identical tableware samples for different testing scenarios).

3. Laboratory Testing and Data Recording

The testing institution conducts tests in accordance with the established scheme, for example: soaking ceramic bowls in acidic solution (simulating vinegar holding) to detect the leaching amount of lead and cadmium in the solution; heating plastic fresh-keeping boxes with oily substances to test total migration. Data is recorded in real time during the test to ensure the results are true and traceable.

4. Report Review and Compliance Judgment

After the test is completed, engineers review all data to determine compliance with LFGB limits. If all items meet the standards, a bilingual Chinese/English or Chinese/German test report will be issued (German reports are usually required for the German market); if an item fails (e.g., excessive heavy metal migration), rectification suggestions will be provided (e.g., replacing glaze materials, adjusting production processes), and retesting will be conducted after the enterprise completes rectification.

5. Market Supervision Preparation and Marking

After obtaining a qualified report, enterprises can mark the product or packaging with the "LFGB compliant" logo (ensuring standard marking and no exaggerated promotion). Meanwhile, the test report must be retained for random inspections by German customs or market supervision authorities — if the product is spot-checked in the market, the compliance certificate must be provided in a timely manner to avoid being deemed a "non-compliant product".

Avoid Three Common Misunderstandings of LFGB Compliance

1. "Only EU CE certification is needed, no LFGB certification required": Incorrect. CE certification is the basic EU access requirement, while LFGB is a more stringent specific requirement for food contact materials in Germany. Even if a product has passed CE certification, it cannot enter the German market if it fails to meet LFGB standards.

2. "If finished products are certified, raw materials do not need to be managed": High risk. If raw materials (e.g., plastic pellets, ceramic glazes) themselves contain excessive substances, finished products will still fail the test. It is recommended that enterprises require suppliers to provide LFGB compliance certificates when purchasing raw materials to control risks from the source.

3. "One certification is valid for a lifetime": Not entirely true. If there are changes in the product's materials, production processes or formulas (e.g., replacement of plastic additives), LFGB retesting is required; if the standard is updated (e.g., LFGB adds limits for certain substances), recertification in accordance with the new requirements is also necessary.

For enterprises looking to explore the high-end food contact material markets of Germany and the EU, LFGB certification is not only an "access permit" but also a "trust endorsement". It is recommended that enterprises integrate LFGB compliance thinking into the product design stage (e.g., selecting standard-compliant raw materials, avoiding high-risk additives), and then complete the certification process efficiently with the assistance of professional testing institutions.