Processing of test reports for stainless steel and silicone (EU EC) No. 1935/200
Date：2026-03-18 10:07:53 Classification
：【question】 Visits：
This document outlines the process, key points, and frequently asked questions regarding obtaining a testing report for stainless steel and silicone products that comply with EU Regulation (EC) No 1935/2004. This regulation is the EU's framework regulation on food contact materials and articles. The core of the "test report" you mentioned is proof that the product complies with this framework regulation and its corresponding specific measures.
I. Core Regulations and Requirements
1. Framework Regulation: (EC) No 1935/2004
◦ This is the general outline, requiring all food contact materials to be safe, not to migrate their components into food and pose a threat to human health, and not to cause unacceptable changes in food.
◦ It stipulates the requirements for "declaration of conformity" and "traceability."
2. Specific Enforcement Standards:
◦ For stainless steel, it must comply with the specific requirements for metals and alloys in EU Regulation (EU) No 10/2011 (regarding plastic food contact materials), as well as the strict limits on heavy metal migration in national regulations such as the German LFGB and the French DGCCRF.
◦ For silicone, it is considered a type of plastic and must fully comply with Regulation (EU) No 10/2011, including:
▪ Total Migration: The upper limit of the total amount of all substances migrating into food simulants under specific conditions.
▪ Specific Migration Limits: Limits on the migration of certain hazardous substances (such as certain heavy metals, primary aromatic amines, etc.).
▪ Sensory Testing: Ensuring that no off-flavors or tastes are transferred to food.
II. Test Report Processing Procedure (Taking Dezeway as an Example)
Steps Specific Content
1. Consultation and Application Contact Dezeway to clarify product information (stainless steel type/silicone grade), specific application (what food will it come into contact with, temperature, and time), and target EU countries.
2. Sample Submission and Evaluation Provide representative samples. Laboratory engineers will determine the applicable regulations and testing items based on your product information.
3. Determine the Testing Plan: The laboratory will provide a detailed quotation and testing plan, specifying: • Stainless Steel: Typically tests for heavy metal migration (lead, cadmium, nickel, chromium, manganese, etc.), conducted in specific food simulants (e.g., acidic solutions). • Silica Gel: Tests for total migration, specific migration, volatile organic compounds, and sensory evaluation.
4. Testing and Reporting: The laboratory conducts tests according to standards and issues a CNAS/CMA accredited test report in both Chinese and English. The report will clearly state the conclusions, indicating whether the sample complies with specific requirements of regulations such as (EU) No 10/2011.
5. Technical Support Documents: You may also need a Declaration of Conformity. This is a legal document issued by you (the manufacturer) declaring that the product complies with regulations such as (EC) No 1935/2004. The test report is important technical evidence supporting this declaration.
III. Key Considerations
1. A "Test Report" is not the same as a "Certificate": Third-party laboratories (such as Dezeway) issue test reports. EU law requires manufacturers to issue their own declarations of conformity. The report is the technical basis supporting this declaration.
2. Overall Product Testing: Test results for the final product (such as a silicone spatula) are more convincing than tests on the raw material (silicone sheet) alone, as they encompass the combined effects of adhesives, inks, and all other components.
3. Differentiating Between New and Old Materials: For silicone, regulations have stricter requirements for "new" materials, typically requiring proof of compliance with the positive list of (EU) No 10/2011.
4. Market Surveillance: Products are subject to random inspections by market surveillance authorities in the EU market at any time. A test report from an authoritative laboratory is your strongest evidence for dealing with inspections and mitigating risks.
IV. Recommendations
1. Direct Communication: Contact Dezeway's technical sales or customer service immediately, providing clear pictures of the product, material specifications (e.g., 304/316 stainless steel, food-grade certification for silicone), and intended use. This is the fastest way to obtain an accurate quote and solution.
2. Define your needs: Inform them that you require testing for food contact materials for "EU market access," aiming to obtain a report supporting the Declaration of Conformity (EC) No 1935/2004.
3. Prepare samples: Prepare samples of the final product to be tested in advance to expedite the testing process.
In summary, obtaining EU food contact testing reports for stainless steel and silicone materials hinges on migration testing based on specific regulations such as (EU) No 10/2011. You need to find a qualified laboratory like Dezeve to perform the testing and prepare the Declaration of Conformity documents accordingly to legally sell your products in the EU.
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