What are the procedures for obtaining a French DGCCRF certification report for p
Date：2025-11-19 09:32:14 Classification
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The core process for DGCCRF certification (Declaration of Conformity) required for exporting paper cups to France, summarized based on French food contact material regulations (especially the DGCCRF regulation), consists of 5 key steps:
I. Preliminary Preparation: Regulatory and Standard Confirmation
1. Identification of Applicable Regulations
- EU Level: Comply with Framework Regulation (EC) No 1935/2004 (General Requirements for Food Safety), Plastics Specific Regulation (EU) No 10/2011 (if plastic coating is involved), and Heavy Metal Limits Directive 84/500/EEC (applied to printing inks for ceramic applications).
- French Specific Requirements: Focus on migration limits for paper products (e.g., formaldehyde ≤15mg/dm²), prohibitions on azo dyes, and fluorescent whitening agents as specified in the DGCCRF notification.
- Other Standards: Refer to EN 13432 (compostability, if applicable) and ISO practical performance tests (leakage resistance, temperature resistance).
2. Material Composition Analysis
- Establish complete supply chain documentation (base paper, coatings, inks, adhesives), ensuring all components comply with the (EU) No 10/2011 Annex I Permitted List (for plastics).
II. Mandatory Performance Testing Phase
Must be conducted in a French accredited laboratory (e.g., DEZEW Testing CNAS Registration No.: L8083):
1. Migration Testing
- Comprehensive Migration Testing: Simulates actual usage conditions (e.g., 40°C, 10 days) to test the total amount of non-volatile substances (limit 10 mg/dm²).
- Specific Migration Testing: Targets high-risk substances such as heavy metals (Pb/Cd ≤0.2 mg/dm²), plasticizers (e.g., DEHP ≤1.5 mg/kg), and primary aromatic amines (prohibited).
2. Material-Specific Testing
- Paper Substrate: Formaldehyde (distilled water migration method), pentachlorophenol (PCP) residue, fluorescent substances (UV lamp screening).
- Printing Inks: Total heavy metals (Cd/Pb/Hg/Cr⁶⁺), polycyclic aromatic hydrocarbons (PAHs), and solvent residues.
- Plastic Coatings: Comply with QM limits in (EU) No 10/2011 (e.g., BPA ≤ 0.05 mg/kg).
3. Physical Performance Verification
- Hot beverage cups must pass a 95°C/30min filling test (no deformation, leakage); cold beverage cups must verify 4°C stability.
III. Technical Document Compilation (Core Compliance Evidence)
Compile a technical file containing the following:
- Product Specification Sheet: Material composition table, process flow diagram, Supplier Declaration of Conformity (SDoC).
- Test Report: Complete original laboratory data and a French summary version approved by DGCCRF.
- Draft Declaration of Conformity (DoC): Includes product identification, applicable regulatory clauses, and a corporate responsibility statement (must be signed by the legal representative).
- Risk Assessment Report: Analysis of toxicological data on migrating substances and expected usage scenarios (e.g., high-temperature contact time).
IV. DGCCRF Application and Filing
1. Submission Method
- Submit online through the French e-government platform (e.g., SERVICE PUBLIC) or mail to the Regional Competition and Consumer Fraud Prevention Authority (DRCCRF).
2. Document Requirements
- Technical file (French version), original DoC, and proof of company registration (foreign companies need information on their authorized EU representative).
3. Filing Validity
- DGCCRF typically does not conduct pre-approval, but the file must be readily available for inspection (retained for 10 years after the product is withdrawn from the market).
V. Subsequent Compliance Management
1. Labeling Standards
- Mandatory labeling: "Food Contact Material" symbol (cup and fork icon), usage conditions (e.g., "max 90°C"), and manufacturer/importer address.
- Compostable paper cups must indicate the applicable standard (e.g., "OK compost HOME").
2. Market Surveillance Response
- DGCCRF may conduct random inspections (retesting of commercially purchased samples). Companies must retain production batch records for traceability.
- Violation penalties: Product recall, fines of up to 10% of annual turnover (Article L. 454-4 of the French Consumer Code).
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