Lunch box EU EC) NO 1935/2004 food contact material testing process
Date：2025-09-12 10:15:10 Classification
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Food contact materials refer to materials and products that come into contact with food during normal use. According to EU Regulation (EC) No. 1935/2004, lunch boxes as food contact materials must undergo the following testing procedures to ensure safety. The core requirements for different materials (such as plastic, stainless steel, and coatings) are summarized below:
I. Preliminary Preparation Phase
1. Selecting a Testing Agency and Confirming Standards
- Select an EU-approved testing laboratory and identify applicable standards:
- For plastic lunch boxes, prioritize compliance with (EU) No. 10/2011 (Plastics Specific Regulation);
- For stainless steel lunch boxes, additionally refer to EN 601/EN 602 (Heavy Metal Migration Standards);
- For lunch boxes with organic coatings, comply with AP(2004)1 (Coating Migration Test).
- Confirm the lunch box's usage conditions (maximum temperature, contact time, and food type). For example:
- Microwaveable lunch boxes require high-temperature migration testing (e.g., above 100°C);
- For contact with acidic foods, simulate a 4% acetic acid solution test.
2. Documentation and Sample Preparation
- Submit product technical documentation (material composition, production process);
- Provide representative lunch box samples (including different colors/batches).
II. Core Testing Items
Select test combinations based on material (referenced standards are shown in the table below):
| Material Type | Mandatory Testing Items
| Plastic (PP/PC, etc.) | Global Migration, Plasticizers (O-phthalates), Bisphenol A
| Stainless Steel/Metal | Heavy Metal Migration (Nickel, Chromium, Manganese, Lead, Cadmium)
| Organic Coating (Non-stick Coating) | Coating Adhesion, Formaldehyde Emission
| Silicone/Rubber Parts | Global Migration, Nitrosamine Content
> Note:
> - Global Migration Test: Simulates oil (olive oil substitute), acidic, and aqueous environments to test total non-volatile matter;
> - Specific Migration Test: Targets harmful substances such as heavy metals (lead ≤ 0.1 mg/L), plasticizers, and other harmful substances.
III. Laboratory Testing Process
1. Migration Test:
- Immerse lunch box fragments in a simulated liquid (e.g., 4% acetic acid, olive oil) and treat at the actual temperature and time required for actual use.
- Example: Boil a stainless steel lunch box in 4% acetic acid for 24 hours and measure the amount of nickel and chromium leaching.
2. Physical Property Testing:
- Coating adhesion (scratch test), heat resistance, and impact resistance.
3. Sensory Evaluation:
- Check for odor, discoloration, or surface changes.
IV. Reporting and Compliance Certification
1. Preparation of Test Report:
- The laboratory issues a detailed report including the test method and comparison limits for the results.
2. Labeling Compliance Review:
- Lunch boxes must be labeled with the "Food Contact" label or the knife and fork symbol, indicating the conditions of use (e.g., temperature range).
3. Additional Member State Requirements:
- Exports to Germany require compliance with the LFGB (additional restrictions on phthalates), while exports to France require DGCCRF certification.
V. Time and Cost Reference
- Turnaround: 5-7 working days for standard testing, extending to 2 weeks for complex materials (e.g., multi-layer composites);
- Cost: Basic testing for plastics is approximately €800-1500, while testing for stainless steel increases due to the increased number of heavy metal items.
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