Food-Contact-Material (FCM) Compliance Pages on Changzhou Manufacturer Websites: How Should They Be Accepted?

Direct answer: EU food contact material (FCM) compliance is not "use food-grade plastic and attach a test report" and you are done. Every material/article that contacts food must meet framework Regulation 1935/2004 (safety, inertness, labelling, traceability, declaration of compliance), be produced under GMP 2023/2006, and be assessed under the specific material rules (plastics 10/2011, ceramics 84/500/EEC, etc.); plastics also require the authorised substance list, SML/OML, food simulants and migration testing. A manufacturer's FCM/food-contact compliance page should state which materials/components contact food, the applicable rules, the DoC, migration testing, BPA/PFAS restrictions, recycled plastics, labelling/traceability and customer data. Otherwise, when an EU customer asks "where is the DoC, under which migration conditions was it tested, what about the BPA ban, how do you treat multilayer materials," the answer becomes an ad-hoc explanation.

This guide is for food packaging, containers, tableware, food machinery, appliances (coffee machines/water dispensers), and paper/plastic/metal/glass/ceramic and coating/ink/adhesive manufacturers in Changzhou and nearby areas. It explains how to write and accept an FCM/food-contact compliance page. Information is current to 2026-11-05. It is a review of public rules and project practice, not EU legal, food-contact safety, migration-testing or compliance advice; the specific scope, testing, DoC, restrictions and prohibitions depend on the regulation, Commission guidance, testing laboratories and the competent authority.

How does the FCM page relate to PPWR, REACH, RoHS, BPA and China GB pages?

The PPWR page answers packaging and packaging waste; the RoHS/REACH page answers material substances/SVHC; the BPA page answers bisphenol A restrictions; China GB 4806 is the Chinese food-contact standard; the FCM page answers "is it safe in contact with food, how much migrates, are the DoC/labelling/traceability complete". PPWR governs packaging waste and does not replace FCM food safety; RoHS/REACH govern substances and do not replace FCM migration/DoC. One food package may be subject to PPWR, FCM, REACH and BPA at the same time.

Common breakpoints: treating PPWR as FCM; treating "food grade" as compliance; having only a plastics report and missing coatings/inks/adhesives/gaskets; a DoC without food type/use conditions; migration testing with the wrong simulant/time/temperature; testing only one layer of a multilayer material; still using BPA after the transition; recycled plastics without 2022/1616 evidence; labelling that only says "food grade". A page that states scope, rules, DoC, testing, restrictions, labelling and red lines gives R&D, quality and export sales one playbook.

This page map is editorial; FCM duties follow Regulation (EC) 1935/2004, the specific material rules and the European Commission FCM page.

Which materials/articles are in the FCM scope?

FCM includes all materials/articles that contact food: packaging, containers, cutlery/kitchenware, food-processing machinery, conveyor belts, pipes/valves, tanks, coffee machines/water dispensers, coatings/inks/adhesives/gaskets. Materials include plastics, paper/board, glass, metal, ceramics, rubber, silicone, coatings and recycled plastics; the EU has specific rules such as plastics 10/2011 and ceramics 84/500/EEC, while other materials are often covered by Member State/national rules, but 1935/2004/GMP still apply.

Common misjudgements: counting only packaging and missing machinery/pipes/tableware; counting only plastics and missing coatings/inks/adhesives/gaskets; counting only the "contact surface" and missing multilayer/composite; treating "food grade" as a regulation; excluding food machinery exported to the EU; treating recycled plastics as virgin. Scope is confirmed by "does it contact food/contact type/material/use conditions"; the page can explain how the company assesses/supports, but must not declare a whole machine compliant for the customer.

Scope follows 1935/2004, specific material rules and Member State rules; confirm specific products with compliance/testing experts.

How should the 1935/2004 framework requirements be accepted?

1935/2004 requires FCM, under normal/foreseeable use, not to endanger health, not to cause an unacceptable change in food composition, and not to change sensory characteristics; it requires labelling ("for food contact" or specific use conditions/safety warnings), traceability (one step up and one step down) and a declaration of compliance (DoC); production must follow GMP 2023/2006. The framework applies to all materials, with specific material rules/national rules on top; the DoC must demonstrate conformity with the framework plus the specific rules.

Acceptance checks: safety/inertness statement; labelling; traceability; DoC; GMP; specific material rules; document version. Common gaps: no DoC; labelling only "food grade"; broken traceability; missing GMP records; citing only 1935/2004 without the specific rule; a DoC that does not match the article/use.

Framework requirements follow 1935/2004, GMP 2023/2006 and Commission guidance.

How should plastics 10/2011 and migration testing be accepted?

Plastic FCM falls under 10/2011: only EU-authorised substances (Union list), compliance with SML (specific migration limit)/OML (overall migration, usually 10 mg/dm² or 60 mg/kg), use restrictions/purity; select the simulant by food type (aqueous/acidic/alcoholic/fatty/dry) and test at the worst-case time/temperature; repeated use requires repeated migration testing; multilayer/composite must consider each layer/the whole. The DoC must list substances/restrictions/test conditions/results.

Acceptance checks: material/layer structure; authorised substances; SML/OML; simulant/time/temperature; repeated use; test report consistent with the DoC; worst case. Common gaps: wrong simulant; single test only; ignoring coatings/inks; testing only one layer of a multilayer; SML/OML exceedance; report model does not match the article; DoC without test conditions.

Plastics/migration requirements follow 10/2011, EU reference laboratory guidance and testing-laboratory opinion.

What should the DoC (declaration of compliance) contain?

A DoC should state: manufacturer/address, product/material/layer structure, food-contact type/use conditions (time/temperature/food type), applicable rules (1935/2004, 10/2011 etc.), authorised substances/restrictions, migration test conditions/results, the declaration of conformity, and signature/date/version. The DoC must cover the specific product/formulation/use, not be a company-wide "food-grade statement"; it must be updated when the formulation/supplier/use changes.

Acceptance checks: product/material; food type/conditions; rules/standards; test conditions/results; signature/version; consistency with the report/label. Common gaps: no food type/conditions; only "complies with 1935/2004"; no test results; model/formulation mismatch; no signature/date; one DoC covering all products.

DoC content follows 1935/2004, 10/2011 and the specific material rules/Commission guidance.

How should the BPA ban and other restrictions be accepted?

Commission Regulation (EU) 2024/3190 applies from 2025-01-20 and bans BPA in food-contact plastics, varnishes/coatings, printing inks, adhesives, ion-exchange resins, silicone and rubber (with limited exceptions in Annex II); the main transition period ran to 2026-07-20, certain preserved fruit/vegetable and fishery product packaging to 2028-01-20, single-use articles may still be filled until 2027-07-20 (certain products until 2029-01-20), and repeat-use/professional equipment stocks may remain available until 2029-01-20; Regulation (EU) 2026/250 corrected the transition periods. BPA also has a separate declaration-of-compliance requirement (Annex III of 2024/3190). PFAS in food-contact packaging is separately restricted under PPWR; specific materials also have SML/heavy-metal/primary aromatic amine limits. The DoC/testing must cover these restrictions, not only overall migration.

Acceptance checks: BPA declaration/testing; coatings/inks/adhesives/silicone/rubber; transition/stocks; PFAS (if applicable); other SML; supply-chain declarations. Common gaps: testing only the plastic body; missing can lining/ink/adhesive; still using BPA after the transition; no supply-chain declaration; confusing PFAS with PPWR; old formulation/stock not cleared.

BPA/other restrictions follow 2024/3190, 10/2011, the specific material rules and Commission guidance; transition dates follow the official text.

How should non-plastic materials, recycled plastics and GMP be accepted?

Non-plastic materials: ceramics fall under 84/500/EEC (lead/cadmium migration); glass/metal/paper/rubber/silicone/coatings/inks are often covered by Member State/national rules plus 1935/2004/GMP; check the target-market national rules. Recycled plastic FCM falls under 2022/1616 (recycling process/source/decontamination/authorisation), so not "any rPET is usable". GMP 2023/2006 requires quality assurance/documentation/traceability/non-conforming product control.

Acceptance checks: material type/target country; ceramic lead/cadmium; paper/metal/coating national rules; recycled plastic process/source/authorisation; GMP records; traceability. Common gaps: assuming non-plastics are out of scope; testing ceramics only visually; recycled plastics without 2022/1616; missing GMP documents; national rules not checked; unknown recyclate source.

Non-plastics/recycling/GMP follow 1935/2004, 84/500/EEC, 2022/1616, 2023/2006 and Member State rules.

Which FCM data will customers ask suppliers for?

Typically: product/material/layer structure, food-contact type/use conditions, applicable rules, DoC, migration test report (simulant/time/temperature/results), authorised substances/SML/OML, BPA/PFAS declarations, ceramic lead/cadmium, recycled-plastic evidence, GMP/traceability, labelling/instructions and change notification. The data must map to a specific product/formulation/use, not a company-wide "food-grade statement".

Deliver an "FCM data pack": cover (manufacturer/date/version/contact) + product/material + food type/conditions + DoC + test reports + restriction declarations + GMP/traceability + labelling + change record. What customers fear most is "a DoC without conditions, the wrong simulant, untested coatings, BPA still in use, model mismatch." Version and access-control the pack.

This data list is editorial; specific fields/formats follow the customer contract, regulations and testing-laboratory requirements.

How should the website FCM page be written?

A public page should include: applicable products/materials/food-contact surfaces, the regulatory framework (1935/2004/GMP/10/2011/specific material rules), DoC/testing, BPA/PFAS/heavy-metal restrictions, recycled plastics, labelling/traceability, customer data request, changes/version and contact. Write verifiably: state material/food type/testing/DoC; do not just write "food grade/complies with FDA".

Separate "public information" from "customer documents": DoCs/test reports/formulations are provided per customer/contract, while the public page explains coverage/process; do not publish customer formulations/supplier information. If supplying components, state that the company supports the machine builder with contact-surface/DoC data and do not declare the whole machine compliant. Multilingual pages should match sales countries; US FDA/China GB 4806 do not replace EU FCM and must be stated separately.

This page structure is editorial; external claims must be truthful and verifiable, per the regulations, testing laboratory, customer contract and competent authority.

What must not be written?

High-risk claims: "food grade = compliant" (not a regulatory term); "FDA-compliant means EU-compliant" (different systems); "an overall migration report is enough" (SML/authorised substances/restrictions also apply); "BPA is no longer a concern" (2024/3190 already applies); "PFAS only concerns packaging" (FCM can also be involved); "any rPET is usable" (2022/1616); "all products pass" (scope/formulation); "the DoC is valid forever" (formulation/use/rule changes require updates). These are inaccurate or misstate responsibility.

Safer wording: "complies with 1935/2004/10/2011, food type/conditions..., DoC/test reports available on request"; "BPA/PFAS declared per 2024/3190/applicable rules"; "recycled plastics per 2022/1616". External promotion must also comply with advertising/fair-competition law; customer names/cases need authorisation.

These red lines are editorial; whether a claim is false advertising/non-compliant is determined by regulators and the contract, and this is not legal advice.

Go-live acceptance checklist

Ten checks: scope/materials, food type/conditions, regulatory framework, DoC, migration testing, BPA/PFAS/heavy metals, recycled plastics/GMP, labelling/traceability, customer data pack, and page wording/version. Each needs an owner, evidence and review date. The pass condition is not "the page says food grade", but that a customer can see what food the product contacts, under which conditions it was tested, and whether the DoC/restrictions are complete.

Before go-live, run one real product through: scope → material/layers → food type → rules → DoC → testing → restrictions → labelling → data pack → page wording. Any step that fails is a gap in the page or the process.

This checklist is editorial; specific compliance requirements follow the regulations, testing laboratory, customer contract and competent authority.

Who should read this, who should not, and what decisions does it support?

It suits manufacturers in Changzhou and nearby areas that export food packaging, containers, tableware, food machinery, appliances (coffee/water machines), paper/plastic/metal/glass/ceramic/coating/ink/adhesive and recycled plastics to the EU. It also suits R&D, quality, export sales, legal and website teams assessing an FCM page. It does not suit businesses that do not sell to the EU, whose products do not contact food, or want one page to replace testing/DoC/legal advice.

Read it if an EU customer is pressing for a DoC/migration test/BPA declaration; you are preparing new packaging/material/markets; you are building or revising an FCM page; or you need to separate PPWR, REACH/RoHS, BPA, GB 4806 and FCM. Skip it if you treat "food grade" as compliance, test only overall migration, or still use BPA after the transition. It supports self-review of scope, rules, DoC, testing, restrictions, labelling, data pack and page wording.

This reader table is editorial; roles and decisions depend on the company's organisation.

FAQ

Which regulations apply to food contact materials?

Framework 1935/2004 (safety/inertness/labelling/traceability/DoC) + GMP 2023/2006 + specific material rules (plastics 10/2011, ceramics 84/500/EEC, etc.); other materials are often covered by Member State/national rules. BPA is separately covered by 2024/3190, recycled plastics by 2022/1616.

What should the DoC contain?

Manufacturer/product/material, food type/use conditions (time/temperature), applicable rules, authorised substances/SML/OML, migration test conditions/results, declaration of conformity, signature/date/version; it must cover the specific product/formulation/use and be updated when the formulation/supplier/use changes.

How should migration test conditions be selected?

Select the simulant by food type (aqueous/acidic/alcoholic/fatty/dry) and test at the worst-case time/temperature; repeated use requires repeated migration testing; multilayer/composite must consider each layer/the whole; results must meet SML/OML. Details follow 10/2011 and the testing laboratory's method.

How are multilayer/composite materials treated?

Identify every layer/material that contacts food (including coatings/inks/adhesives/gaskets), confirm each against the applicable rules/restrictions, then assess overall migration; do not test only the substrate or one layer. The layer/test plan is confirmed with the product and the laboratory.

Does the BPA ban apply now?

2024/3190 applies from 2025-01-20 and bans BPA in food-contact plastics/coatings/inks/adhesives/ion-exchange resins/silicone/rubber (with limited exceptions); the main transition ran to 2026-07-20, certain preserved product packaging to 2028-01-20, single-use articles may still be filled until 2027-07-20 (certain products until 2029-01-20), and repeat-use/professional equipment stocks may remain available until 2029-01-20; 2026/250 corrected the transition periods. Follow the official text/amendments.

Can China GB 4806 replace EU FCM?

No. GB 4806 is the Chinese food-contact standard; the EU requires 1935/2004/10/2011 etc., a DoC, migration testing and labelling/traceability. Exporting to the EU means following EU rules, not only a GB 4806 or FDA report.

One-sentence takeaway

A Changzhou manufacturer's FCM/food-contact page is not about the words "food grade". It should turn scope/materials, food type/conditions, 1935/2004/10/2011, the DoC, migration testing, BPA/PFAS/heavy metals, recycled plastics/GMP, labelling/traceability and the customer data pack into a verifiable checklist—so a customer can see what the product contacts, under which conditions it was tested, and whether the DoC/restrictions are complete.

Method and limitations

This is a review of public rules and project practice, not an audit or legal opinion on any company's products, materials, migration testing, DoC or food safety. No undisclosed customer formulation/testing/supply-chain data were used. Scope, rules, testing, restrictions and acceptance items are editorial suggestions, not testing/compliance/legal conclusions. Specific scope, testing, DoC, restrictions and prohibitions depend on the regulation, Commission guidance, testing laboratories and the competent authority.

Sources and scope

Information is current to 2026-11-05. The following are EU official/legal pages; their articles, annexes and guidance control.

1. Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food, adopted 27 October 2004: EUR-Lex. Framework safety/inertness/labelling/traceability/DoC.
2. Commission Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food, adopted 14 January 2011: EUR-Lex. Authorised substances, SML/OML, simulants, migration testing, DoC.
3. Commission Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food, adopted 22 December 2006: EUR-Lex. GMP.
4. Commission Regulation (EU) 2024/3190 on the use of bisphenol A and other bisphenols in food contact materials, adopted 19 December 2024 and corrected as regards transition periods by Commission Regulation (EU) 2026/250: EUR-Lex. BPA ban/exceptions/transition/declaration of compliance.
5. European Commission, Food Contact Materials: European Commission. FCM scope, 1935/2004/GMP, plastics/ceramics, recycled plastics and rule amendments.