Stainless steel cups and tableware EU EC) NO 1935/2004 testing methods and proce
Date：2025-09-25 10:07:18 Classification
：【question】 Visits：
The EU framework regulation for food contact materials is (EC) No 1935/2004. It has evolved to cover materials such as plastics (EU) No 10/2011, regenerated cellulose films (2007/42/EC), ceramics (84/500/EEC), rubber (93/11/EEC), and active and intelligent materials (EC) No 450/2009. This detailed description of the testing methods and procedures for food contact materials under EC No. 1935/2004 for stainless steel cups and tableware exported to the EU is compiled in conjunction with EU regulations and laboratory operating procedures:
I. Core Testing Items and Standards
According to EU Regulation (EC) No 1935/2004 and its accompanying standards, stainless steel tableware must be tested for the following key items:
1. Heavy Metal Migration Test (Key Item)
- Test substances: nickel (Ni), chromium (Cr), manganese (Mn), lead (Pb), and cadmium (Cd).
- Limit requirements:
- Nickel ≤ 0.1 mg/L, chromium ≤ 0.1 mg/L, manganese ≤ 0.1 mg/L (simulating acidic food conditions).
- Test method:
- Boil the sample in a 4% acetic acid solution for 24 hours (simulating acidic food contact).
- Quantitative analysis of migration using ICP-MS (Inductively Coupled Plasma Mass Spectrometry).
2. Surface Coating Adhesion Test (if coated)
- Applicable products: Stainless steel cups with organic coatings (e.g., anti-scalding paint, colored patterns).
- Method: Scratch test (Tape Test) or tape peeling method to assess whether the coating has fallen off.
3. Other Risk Substance Testing
- Migration of arsenic (As), cobalt (Co), etc. (according to EN 13882).
II. Testing Process and Steps
Phase 1: Preliminary Preparation
1. Sample Requirements:
- Provide 3-5 finished products from the same batch, including all material components (e.g., silicone lid ring, plastic handle).
- Indicate product usage conditions (e.g., maximum heat resistance temperature, food contact type).
2. Document Submissions:
- Product technical drawings, bill of materials (BOM), supply chain compliance statement (e.g., stainless steel grade certification).
Phase 2: Laboratory Testing Process
| Steps | Operation Details
| Pretreatment | Clean the sample and simulate actual use scenarios (e.g., high-temperature sterilization)
| Migration Test | Boil 4% acetic acid solution for 24 hours (100°C ± 2°C). Collect the solution and test for heavy metal migration.
| Coating Adhesion | Rasterize the coated area (1mm x 1mm), apply special tape, and quickly peel off the tape to observe the area of detachment.
| Chemical Analysis | ICP-MS to test the heavy metal content in the migration solution; GC-MS to screen for organic contaminants (if plastic components are included).
Phase 3: Report Production and Certification
- Turnaround: 5-7 working days (expedited to 3 days).
- Report Contents:
- Test method, limit comparison, and compliance conclusion (with EU-accredited laboratory stamp).
- Declaration of Conformity (DoC), indicating the product's applicable temperature range (e.g., "for food ≤ 100°C").
III. Special Considerations
1. Differences in Member State Requirements:
- Exports to Germany require additional compliance with LFGB: sensory testing (odor assessment) + comprehensive migration testing.
- Exports to France require compliance with DGCCRF: formaldehyde migration testing (if composite materials are involved).
2. Common Causes of Failure and Improvements:
- Excessive nickel/chromium: Use low-carbon stainless steel (e.g., 316L instead of 304) to reduce the risk of high-temperature migration.
- Coating Delamination: Optimize the spraying process and improve primer adhesion.
3. Labeling and Compliance Marking:
- "Complies with (EC) No. 1935/2004" and the cutlery symbol must be marked.
- Restrictions on use (e.g., "Not suitable for microwave ovens") must be indicated.
IV. Business Operational Recommendations
1. Cost Optimization:
- Prefer CNAS/CMA dual-accredited laboratories. The testing fee per unit is approximately ¥1,000-3,000 (depending on the complexity of the component).
- Obtain RoHS/food grade reports from raw material suppliers in advance to reduce repeated testing.
Shen Gongwang Security: 44030602006947