Insights · 2026-10-03

For kitchenware, ask about the material before the product

Food contact is the one category in this series cut a different way. The others are cut by product; this one is cut by material. A single shelf can hold two bowls that fall under two regulations, two reports and two conformity routes.

Material first, product second

Compliance questions about kitchenware do not get far if they start from the product. A bowl can be ceramic, melamine, stainless steel, glass, bamboo or non-stick coated, and each material can fall under a different regulation in the same market.

So the order has to be reversed: establish the material, then the product form and conditions of use (fatty contact, maximum temperature, repeated use), and only then which test report and which declaration are needed. Reverse the order and the report you get back is the wrong one.

EU: one framework, several material-specific measures

The EU structure has two layers. The upper layer is the framework Regulation (EC) No 1935/2004, which sets general principles: materials must not transfer constituents into food in quantities that endanger health, must not change the composition of the food, and must not mask deterioration. It also sets labelling and traceability requirements and requires a declaration of conformity.

The lower layer is material-specific. Plastics go under (EU) No 10/2011, which has a positive list of permitted monomers and additives and two kinds of migration limit, overall and specific. Ceramics go under 84/500/EEC, which covers lead and cadmium migration and requires a declaration of conformity. Metals, paper, coatings, inks and adhesives each have their own measure.

The practical conclusion for a buyer: EU food contact evidence is a declaration of conformity plus the test reports behind it, not a certification mark. The supplier issues the declaration and carries the responsibility; the buyer's job is to check that the regulations and test items cited match the actual product.

The EU list keeps moving

The positive list and migration rules in (EU) No 10/2011 are amended continuously. One amendment adopted in February 2025, (EU) 2025/351, applies from the twentieth day after publication, which by the 24 February 2025 publication date works out to 16 March 2025. The text sets out a transition: certain materials and articles already placed on the market may be sold until stocks run out, and another provision limits certain uses to products placed on the market before 16 September 2026.

The practical meaning is that two shipments of the same goods can fall under different rules depending on which side of a transition date they were produced. On long orders, that belongs in the contract rather than in someone's memory.

US: the route of indirect food additives

The US has no act called food contact materials. It regulates them as indirect food additives under parts 174 to 190 of Title 21: part 174 is general, part 177 covers polymers, and the rest are split by material and use. A substance is either listed in the regulations or cleared through a food contact notification.

The structural difference is that the EU uses a framework plus material measures plus a declaration, while the US uses substance lists plus a notification route. For a buyer the meaning is similar: what is wanted is a technical document that can be traced to a position on a substance list, not a certificate.

Japan: the positive list

Under its Food Sanitation Act, Japan introduced a positive list system for synthetic resins: only substances on the list may be used in food utensils and packaging. The system took effect on 1 June 2020, and the transitional measures expired on 31 May 2025, so full application began on 1 June 2025.

The phrase is worth remembering because a positive list is the opposite of a negative one. It does not say what is banned; it says only what is allowed. A report showing that a substance was not detected may not be enough here. What is needed is that the material itself is on the list.

China: the GB 4806 series, one part per material

China's baseline is the GB 4806 series, also split by material: general requirements, then separate parts for plastics, metals, rubber, coatings, inks, adhesives and composites. This library holds the text of the metal part, GB 4806.9-2023.

Structurally China is closer to the EU: the standard itself carries the safety indicators and migration limits, and the operator carries product liability under the standard and its own declaration. Food contact materials are not in the CCC catalogue, which separates this category from appliances, lighting and toys.

Ten markets side by side

Taking the material-first line across ten markets:

What all ten share is that no single kitchenware certification covers everything. The evidence is always a combination: this material, under these conditions of use, tested against these items.

What to ask before you order

Ask four things about food contact: what the material actually is, meaning a specific grade or material code rather than a phrase like food-grade stainless steel; what the conditions of use are, including fatty contact, maximum temperature and repeated use; which regulation and which test items the report covers, since overall migration, specific migration and heavy metal migration are separate tests; and who issues the declaration of conformity and which models it covers.

The first question is where buyers lose most. Food grade is a marketing phrase, not a material. Two batches of stainless steel cutlery in different grades can give completely different heavy metal migration results, and the quote usually says only stainless steel. To work through these in order, start with the free verification checklist. The previous article in this series is textiles and apparel; the next, cosmetics and personal care, is a different structure again, where standards are not the main actor at all and the responsible person and registration are. To see how test reports and declarations are recorded, look at a report sample, or get in touch.