Food Packaging Paper French DGCCRF Testing Report Process
Date：2025-11-21 10:09:54 Classification
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Food packaging paper exported to France must comply with EU General Regulation (EC) No 1935/2004 and specific French requirements (such as DGCCRF Note 2004-64 and Décret n°92-631). Although DGCCRF does not issue "certificates of certification," it is mandatory to pass its accredited testing programs and retain compliance technical documentation to address market inspections. The following is a complete process for obtaining a French DGCCRF testing report, specifically tailored for food packaging paper products:
I. Scope of Application
Food packaging paper includes, but is not limited to:
Baking paper (for ovens)
Oil paper, greaseproof paper
Food wrapping paper (e.g., sandwich paper, hamburger paper)
Paper bags (bread bags, candy bags)
Food-grade kraft paper with printed designs
Cold/hot beverage paper cup base paper (excluding plastic coating)
If it contains plastic coating (e.g., PE coating), aluminum foil lamination, or ink printing, additional testing of the corresponding materials is required.
II. Core Testing Items (Based on DGCCRF Requirements)
Test Categories
Comprehensive Migration Test
Specific Substance Migration
Hazardous Chemical Residue
Heavy Metal Migration
Fluorescent Whitening Agents
Sensory Test
If the packaging paper contains printing inks: Primary aromatic amines (PAAs), polycyclic aromatic hydrocarbons (PAHs), and solvent residues also need to be tested.
III. Test Report Processing Procedure (6 Steps)
Step 1: Confirm Product Structure and Intended Use
Does it contain a coating (e.g., PE, PLA)?
Is it printed? What type of ink is used (water-based/UV/solvent-based)?
Type of food contact (dry/wet, cold/hot, acidic/greasy)
Usage temperature (e.g., whether it is used in an oven ≤220℃)
Example: Baking paper requires a high-temperature migration test (100℃, 2h); cold drink packaging paper only requires a room temperature test.
Step 2: Sample and Document Preparation
Sample Requirements:
Provide a sample of ≥50g base paper (free from cutting contamination).
If printing is involved, provide a finished sample with the complete design (≥10×10 cm).
Multiple colors/batch batches require separate testing.
Technical Documents:
Raw material composition description (wood pulp source, additive list)
Ink/adhesive supplier declaration of conformity (SDoC)
Brief description of the production process (Is bleaching used? Are recycled fibers used?)
⚠️ France prohibits the use of recycled fibers in the manufacture of paper products that come into direct contact with food!
Step 3: Selecting a Compliant Laboratory
It is recommended to choose an institution with the following qualifications:
CNAS accreditation (e.g., DZW Testing CNAS registration number: L8083)
Familiarity with DGCCRF 2004-64 and EN 648 / EN 13130 standards
Ability to issue English reports with French summaries (for French importers' filing)
Step 4: Laboratory Testing (5–7 working days)
Typical test conditions example (using baking paper as an example):
Total migration: Olive oil, 100℃, 2 hours → ≤10 mg/dm²
Formaldehyde: Distilled water, 40℃, 10 days → ≤15 mg/dm²
PCP/TeCP: GC-MS detection → ND (Not Detected)
Sensory assessment: Odor/taste migration assessed by a 3-person panel
Step 5: Obtaining the Test Report and Technical Documents
The report should include:
Laboratory accreditation mark (CNAS/CMA)
Testing standards (e.g., DGCCRF) 2004-64, EN 13130-1
All test results and conclusions (Pass/Fail)
Sample description, test conditions, instrumentation methods
The company must also prepare:
Declaration of Conformity (DoC)
Technical File: including raw material safety data, production process, and risk assessment
Technical documents must be retained for 10 years after the product is discontinued; DGCCRF may conduct random checks at any time.
Step 6: Labeling and Market Compliance
When sold in the French market, the packaging paper or its outer packaging should be labeled with:
"Pour contact alimentaire" (food contact application)
Applicable temperature range (e.g., "Max 220°C")
Manufacturer/EU authorized representative's name and address
If it is compostable paper, indicate certification marks such as "OK Compost INDUSTRIEL"
IV. Common Failure Reasons and Mitigation Suggestions
Risk Points Solutions
Formaldehyde Excess: Avoid using urea-formaldehyde resin adhesives; use food-grade starch adhesives instead.
Fluorescent Agent Detection: Do not use base paper containing fluorescent whitening agents; purchase "non-fluorescent" food-grade paper.
PCP Residue: Ensure that wood raw materials have not been treated with pentachlorophenol preservatives.
Ink Migration: Use food contact inks that comply with EuPIA GMP.
V. Cost and Time Reference (2025)
Item Cycle
Basic Testing (Unprinted Base Paper) ¥1000–2500 5–7 days
Including Printing/Coating 7–10 days
Express Service (3 days) 3–5 days
VI. Summary:
Food packaging paper entering France must pass migration and chemical residue tests accredited by DGCCRF, with a focus on controlling formaldehyde, PCP, fluorescent agents, and heavy metals. Confirming raw material compliance with suppliers in advance can significantly reduce the risk of test failure.
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