Detailed Explanation of the French DGCCRF Test Report for Aluminized Film
Date：2026-06-30 09:58:47 Classification
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Detailed Explanation of the French DGCCRF Test Report for Metallized Film
I. Overview of DGCCRF
DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes, the French Directorate General for Competition, Consumer Affairs and Fraud Control) is the authoritative body in France responsible for regulating the safety of food contact materials (FCM). All food contact materials exported to or resold through France must comply with its regulations.
II. Product Definition of Metallized Film
Metallized film typically refers to a composite film made from materials such as PET, BOPP, CPP, and PE as the base material, with an aluminum layer formed on the surface through a vacuum evaporation process. It is commonly used in:
Food packaging (e.g., snacks, coffee, milk powder, candy)
Cosmetic packaging
Pharmaceutical packaging
Because it may come into direct contact with food, metallized film is a food contact material regulated by the DGCCRF.
III. Core Requirements of DGCCRF Testing
DGCCRF conducts compliance assessments based on EU Regulation (EC) No 1935/2004 and French local law Décret n°2007-766. The main testing items include:
1. Overall Migration Test
Simulated Liquid: Selected according to food type (e.g., water, 3% acetic acid, 10% ethanol, olive oil, 95% ethanol, etc.)
Test Conditions: Based on actual usage temperature and time (e.g., 10 days @ 40°C, 2 hours @ 70°C, etc.)
Limit Requirement: Total migration ≤ 10 mg/dm² (total surface area in contact with food)
2. Specific Migration Test
For specific substances that may leach from aluminum layers and inks/adhesives:
Aluminum (Al): Migration limit 5 mg/kg (Food Simulation Liquid)
Heavy Metals: Lead, Cadmium, Mercury, Hexavalent Chromium, etc.
Aromatic Amines (from inks/adhesives)
Phytaldehyde Esters (Plasticizers)
Total Primary Aromatic Amines (PAA) ≤ 0.01 mg/kg
3. Sensory Testing (Organoleptic Tests)
Odor Transfer: Does it produce off-odors in packaged food?
Taste Transfer: Does it affect the flavor of food?
Color Change: Does it contaminate the appearance of food?
4. Evaporation Residue Test
Total residual migrations in different simulation liquids
5. Other Special Tests
Aluminum Layer Adhesion (Ensuring the aluminum layer does not peel off during use)
Sealing Test (For composite structures)
Printing Ink Safety (If ink is used, it must comply with Swiss Ordinance or EuPIA standards)
Detection of Sensitive Substances such as Bisphenol A (BPA) and Formaldehyde
IV. Key Contents of the Test Report
A complete DGCCRF compliance report should include:
| Item | Description
| Report Number and Date | Official Laboratory Number
| Applicant/Manufacturer Information | Company Name, Address, Contact Person
| Product Description | Material, Structure (Substrate + Aluminum Layer + Adhesive + Ink), Thickness, Color
| Intended Use | Type of Food Contact, Contact Temperature and Time
| Testing Basis | Regulations (EC 1935/2004, French Decrees, etc.)
| Test Items and Results | Comparison of Detected Values and Limits for Each Item
| Conclusion (Conformity) | Clearly marked "Pass" or "Fail"
V. Compliance Process Recommendations
1. Material Self-Inspection: Clearly define the composition of each layer of the aluminized film (substrate, aluminum purity, adhesive type, ink composition)
2. Laboratory Selection: Select a third-party laboratory accredited by COFRAC France (e.g., Dezewei Testing CNAS Registration No.: L8083)
3. Sample Submission for Testing: Provide sufficient samples as required by the laboratory (usually finished products and raw materials are required)
4. Report Obtaining: The testing cycle is generally... 5-7 business days
5. Use of Declaration of Conformity (DoC): Manufacturers must sign the Declaration of Conformity and file it along with the report.
6. Update Monitoring: DGCCRF regulations are updated periodically; continuous monitoring of the latest limits is necessary.
VI. Common Issues and Risk Warnings
Excessive Aluminum Migration: Prolonged contact with acidic foods (such as juice and tomato sauce) may dissolve the aluminum layer. It is recommended to choose a structure with a protective coating on the inner layer (such as VM-PET or VM-CPP).
Ink Risk: Aromatic amines and solvent residues in the outer layer printing ink may migrate to the inner surface through the composite layer. An ink-free inner layer structure or low-migration ink must be used.
Complete Declaration Documents Required: Test reports alone are insufficient; a Declaration of Conformity (DoC) and a Declaration of Good Manufacturing Practice (GMP) are also required.
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