Legislation on food contact materials

FCMtesting ApS is a Danish testing company based in Odder, just south of Aarhus. We specialize in documentation and testing of food contact materials for manufacturers, importers and food companies throughout Denmark. Our consulting covers current EU and Danish regulations, and we help you ensure full compliance – from testing to finished documentation.

Food contact materials (FCM) are regulated by both EU regulations and national requirements. For companies that produce, import or use materials in contact with food, it is crucial to know and comply with these rules.

EU Regulation 1935/2004 on food contact materials

This regulation sets out the general principles for all materials and articles that come into contact with food. It requires that materials

• do not release substances in quantities that could be harmful to human health,
• do not alter the composition of the food, and
• do not impair the taste, smell, or appearance.

Read EU Regulation 1935/2004 on EUR-Lex

EC Regulation 2023/2006 on Good Manufacturing Practices

The regulation sets out requirements for good manufacturing practice (GMP) for materials and articles intended to come into contact with food. It requires, among other things:

• Establishment of a documented quality assurance system
• Controlled production conditions
• Relevant documentation and traceability

The purpose is to ensure that production takes place under conditions that guarantee the material's compliance with legislation.

Read EC Regulation 2023/2006 at EUR-Lex

Material-specific legislation – plastics and other materials

Plastic materials are covered by EU Regulation 10/2011, which includes detailed requirements for, among other things, authorized substances (Union List), migration limits (SML/TML), and testing conditions. At FCMtesting ApS, however, we test far more than plastics – we work with the full spectrum of materials that may come into contact with food, including silicone, glass, metal, paper, wood, coatings, and much more.

Each type of material may be subject to its own specific regulations, technical guidelines, or national requirements. We stay up to date across all legislation and ensure that your products comply with applicable standards – regardless of the material.

Read EU Regulation 10/2011 on EUR-Lex

In practice, many plastic materials today are not “pure” types of plastic. Plastics are often combined with fillers, pigments, recycled material or organic components to achieve special properties or a more sustainable expression. Such combinations can affect migration behavior and documentation requirements and therefore require a specific assessment in relation to applicable legislation.

See example of assessment, testing and documentation of coffee cups made of plastic combined with coffee grounds.

Food contact in machinery and automated equipment

Food contact is not limited to packaging and consumer products. In many production environments, machinery and automated equipment come into direct or repeated contact with food, e.g. during handling, portioning or further processing. This often raises questions about which components are covered by the rules for food contact materials and how the documentation requirements should be defined in practice.

See example of assessment, testing and documentation of robotic arm with direct food contact in industrial production.

National requirements in Denmark

In addition to EU rules, Danish regulations and guidelines from the Danish Veterinary and Food Administration also apply. These include requirements for documentation, testing methods, and Declarations of Compliance (DoC). Read more at the Danish Veterinary and Food Administration

Some materials require special attention in relation to national regulations. For example, handmade ceramics with special glaze can be challenging because EU regulations only harmonise requirements to a limited extent. Here, national requirements for migration testing and declaration of conformity become crucial for both documentation and safety.

See example of assessment, testing and documentation of ceramics with special glaze for food contact.

Documentation and compliance

At FCMtesting ApS, we help companies to:

• identify relevant legal requirements and material standards,

• perform accredited tests (overall/specific migration, NIAS, etc.),

• prepare Declarations Compliance (DoC), and

• enhance traceability and compliance documentation.

We work closely with both Danish and international companies and offer personal advice so that you avoid unnecessary or costly testing requirements. Our goal is that your products comply with legislation - without compromising on quality or economy.

We document compliance for all types of materials, machinery and equipment. See concrete examples of our work with food contact materials on our [case overview].

Related pages

• Declaration of Compliance
• Food contact materials (overview)
• Testing of plastics
• Testing of silicone
• Testing of glass and ceramics
• Testing of metals
• Testing of wood and bamboo
• Testing of paper and cardboard
• Testing of coatings and colors
• FAQ
• Cases (overview)

Contact us

Address: Ballevej 1, 8300 Odder, Central Jutland, Denmark
Phone: +45 41 20 00 49
Email [email protected]
Accreditation: DANAK registration