Plastic Kitchen Products Regulations in the European Union: An Overview

Planning to import and sell plastic kitchen utensils and other products in the European Union? In this guide, we cover the essentials of EU food contact materials regulations, REACH, EN standards, labeling rules and more.

Mentioned Products

• Silicone kitchen utensil
• Nylon kitchen utensil
• PTFE non-stick cookware
• Plastic lunch boxes
• Plastic food containers
• Plastic cutlery
• Plastic ladle

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EU Food Contact Materials Framework Regulation

EU sets out the rules on the composition of plastic food contact materials (FCMs), and provide a list of permitted substances for use in plastic FCMs. The framework regulation applies all plastic kitchen products such as silicone kitchen utensils.

Importers must ensure that their plastic kitchen products comply with the plastic FCMs regulation. For example, your plastic kitchen products shall not release their constituents into food at levels harmful to human health.

Plastics: Regulation (EU) No 10/2011 and its amendments

Regulation (EU) 10/2011 is within the framework regulation, and it’s specifically intended to regulate plastic kitchen utensils and other food contact materials that are made of plastic, including:

• Plastics mono-layers
• Plastic multilayer bound by adhesives
• Plastic layers or coatings forming gaskets in caps & closures
• Plastic layers in multi-material multi-layer materials
• Plastics that can be coated and/or printed

Restricted substances

The regulation provides the migration limits that specify the maximum amount of substances allowed to migrate to food. The overall migration limit (OML) shall not exceed 60mg/kg food or 10 mg/dm^2 of the contact material.

Further, toxic and non-eco-friendly substances such as single-use plastic are restricted under the EU framework regulations. Note that the regulation is regularly amended, therefore, we recommend that you should book a third-party lab testing for the latest FCM compliance rules.

Also note that lab testing companies, such as QIMA and Bureau Veritas, can help you assess which heavy metals and chemicals to include. All they need to know the product, material and where you intend to sell the products.

Declaration of Compliance (DoC)

Importers must provide DoC for plastic kitchen products to ensure the safety, quality, and compliance of plastic material used in cookware. The DoC must support with relevant documents such as certificates and test reports. You shall also include the following in your DoC:

• Company name
• Company address
• Product name
• Production date
• List of applicable EU FCM regulations/standards
• Types of food or beverage the FCM product is made for
• Treatment (e.g. storage, time and temperature)

Click here to learn more about how to issue a DoC for plastic kitchen products.

FCM lab testing

Some reputable companies such as TUV, SGS, and QIMA, provide a comprehensive FCM lab testing for your plastic kitchen products.

They can verify whether your product meets general safety regulations, and conduct relevant lab testing to ensure regulatory compliance.

Testing costs

In general, FCM testing costs range from $200 to $500 depending on different materials and products. Note that the testing cost is set on a per-product and material basis. As such, testing different variations of the same product (e.g. different colors or coatings) is more costly. That said, most testing companies offer free quotations.

Product Traceability

A traceability code is also required under the EU framework regulation. Importers shall provide and affix a permanent code to the product and its packaging when importing to the European Union. The traceability code shall include information such as:

• SKU
• Manufacturing date
• Production facility
• Country code

Example: SKU-1112-012-CN

GMP

To ensure that your plastic kitchen products, such as nylon utensils or non-stick cookware, is consistently produced and controlled according to quality standards, importers shall comply with the Good Manufacturing Practice (GMP) with the following requirements:

1. Materials are pre-selected and procured to ensure that the finished product is compliant.

2. The production and quality assurance process is carried out according to pre-established instructions, which ensures that the finished product is compliant.

3. Quality control and verification system are established.

4. The production facilities must be fit for purpose.

Importers can self-issue a GMP report that includes details of certifications, quality control processes, lab testing processes, production specifications, and other relevant supporting documents.

Learn more

Check out more details and learn about the GMP on the official EU website.

Risks

Some plastic materials contain excessive amounts of restricted chemicals, such as Bisphenol A, and other substances. Keep in mind that most plastic kitchen products on the market are not made with the generally high EU standards in mind. It’s therefore essential to get products lab tested before placing plastic kitchen products, such as lunch boxes, on the EU market.

Food Contact Material Symbol

Importers must apply the glass and fork symbol shown above on plastic kitchen products unless it’s obvious that the product is an FCM, for example, a plastic drinking glass, or the product already contain food when it’s placed into the market.

REACH

Besides EU specific FCMs regulations, REACH regulation applies to all consumer products sold in the European Union market including plastic kitchen products. Certain hazardous substances are restricted under REACH, and selling plastic kitchen products containing exceed restricted substances is illegal in the European Union.

Examples of restricted substances under REACH include:

• Lead
• Cadmium
• Nickel
• Mercury

Substances of Very High Concern (SVHC)

The candidate list of SVHC provides all restricted substances adopted in the framework of REACH. Importers can refer to the list and verify if your plastic kitchen products are REACH compliant. However, very few importers have access to the list of components and materials of their plastic kitchen products. Therefore, we suggest that you should book a third-party lab testing for most updated REACH compliance.

Lab testing

Third-party lab testing is the only safe way to verify REACH compliance. Lab testing companies such as Bureau Veritas, SGS, and Intertek, provide relevant testing for plastic kitchen products such as PBT testing, Nickel release testing, and PCTs testing. Further, they can verify your product by issuing certification documents.

Testing companies

Here are some companies offering REACH compliance testing:

• C&K Testing
• Bureau Veritas
• Intertek
• SGS

Click here to learn more about REACH lab testing companies.

Costs

The average REACH lab testing costs from $300 to $600 based on two to three materials and color variations. The cost will ultimately depend on the number of materials and colors.

Learn more

Learn more about REACH lab testing in this guide.

Risks

As mentioned, plastic materials are not made to comply with REACH and other EU regulations by default. It’s therefore essential to submit product samples for lab testing before importing to the EU.

General Product Safety Directive (GPSD)

The General Product Safety Directive ensures the product is safe to use, and inform consumers of any risks associated with the product. The GPSD applies to all consumer products including plastic kitchen products sold in the European Union market.

Importers shall assess product safety and risks of their plastic kitchen products product, then create a safety assessment to make a declaration. Note that the target audience shall also include children and infants.

GPSD Documentation

Importers shall establish all potential safety hazards of plastic kitchen products by issue risk assessment documents.

GPSD Testing

GPSD testing is generally not mandatory for plastic kitchen products’ importers. However, third-party lab testing can help importers with a better assessment of the product safety, and prepare relevant documentation.

CE Marking

GPSD does not require CE marking as it is not one of the 25 CE marking directives.

EN Standards

EN standards are established by the European Standards Organizations and serve as a reference for the product design stage to ensure product safety.

EN standards are usually not mandatory for plastic kitchen products. However, it is still beneficial for importers at the product development stage. EN standards set out requirements for testing methods, material options, and production guidelines to maintain high product quality.

Examples of plastic cookware EN standards

• EN 12778 – Cookware. Pressure cookers for domestic use.
• EN 14916 – Domestic cookware. Graphical symbols (pictograms)

Find applicable EN standards for your plastic kitchen products on shop.bsigroup.com.

EN testing

EN standards require professional expertise and equipment. Most importers are not capable to conduct such testing to verify their plastic kitchen products. Instead, importers might consider testing companies such as Intertek, SGS, Bureau Veritas, to carry out EN standards testing.

Directive 94/62/EC: Packaging Regulations

When you are importing plastic kitchen products to the European Union, it is also important to ensure packaging compliance. Here we provide a brief summary of the packaging requirements under Directive 94/62/EC:

Heavy Metals Restrictions

Directive 94/62/EC restricts the use of heavy metals in product packaging. Importers must ensure that the packaging of plastic kitchen products shall not exceed a certain limit when placed in the European market. For example, the total concentration of lead in packaging shall not exceed 100 ppm.

Note: Leading testing companies such as SGS, Intertek, and Bureau Veritas can also provide packaging tests based on directive 94/62/EC or other applicable standards.

Additional Packaging Information

1. Packaging material should be built to simplify material recycling, reuse, and collection purposes.

2. Compliance marks such as CE marking should be also printed on the product packaging.