Process for Obtaining the French DGCCRF Certification Report for Metal Cans
Date：2026-09-14 11:13:59 Classification
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Process for Obtaining the French DGCCRF Certification Report for Metal Cans
As typical food-contact materials, metal cans are a key category subject to DGCCRF regulation. The certification process involves compliance with regulations such as the French *Arrêté du 25 novembre 1992* and EU Regulation 1935/2004/EC, as well as the migration testing requirements specified in Brochure No. 1227.
I. Core Processing Steps (Detailed Seven-Step Overview)
Step 1: Product Classification and Regulatory Identification
Metal cans fall under the category of "metal food-contact materials." Applicable core regulations include:
*Arrêté du 25 novembre 1992*: The fundamental French regulation on food-contact materials.
Regulation (EC) 1935/2004: The EU framework regulation on food-contact materials.
Brochure No. 1227: The official French guideline for migration testing (key reference).
Fiche MCDA: Food-contact material compliance dossier (mandatory document).
For metal cans, special attention must also be paid to the compliance of internal coatings (e.g., epoxy resins, phenolic resins), as substances such as Bisphenol A (BPA), BADGE, BFDGE, phenols, and formaldehyde within these coatings are key targets for DGCCRF testing. Step 2: Select a qualified testing agency
Must be an ISO 17025 accredited laboratory (Dezewei Testing CNAS Registration No.: L8083)
The test report must clearly specify the French standards used, rather than just EU standards
Prioritize agencies with experience in migration testing for metal cans to avoid issuing reports that French Customs will not accept
Step 3: Prepare samples and technical documentation
Required samples and information
Sample quantity: 6–12 finished cans (adjusted based on specific test items)
Complete finished cans (including food simulant for contents)
Separate samples of the internal coating (if provided by the client)
One sample for each specification
Technical documents:
Product specifications
Can structural diagram (including coating type and thickness)
Coating composition/formula information
Welding material information
Sealing gasket information
Step 4: Laboratory testing (Core phase)
Core test items for metal cans
| Test Category | Specific Item | Regulatory Basis | Test Method
| Overall Migration | Total migration limit | 1935/2004/EC | Food simulant immersion
| Specific Metal Migration | Release of Pb, Cd, Ni, Cr, Al, Sn, As, etc. | French Arrêté 1992 | ICP-MS/ICP-OES
| Coating Safety Test | Bisphenol A (BPA) migration | Key French regulation | HPLC-MS/MS
| | BADGE/BFDGE/NOGE migration | EU 1895/2005 | HPLC-MS/MS
| | Phenols, formaldehyde migration | French Arrêté 1992 | Spectrophotometry
| | Aromatic amine migration (aromatic coatings) | French regulations | HPLC
| | Epoxy derivative total migration | 1895/2005/EC | HPLC
| Food Simulant Test | Select 3% acetic acid, 10% ethanol, olive oil, etc., based on can usage | 82/711/EEC | Multi-condition immersion
| Usage Condition Test | High-temperature sterilization, pasteurization, ambient storage | Based on actual use | Simulating actual usage
| Sensory testing | Color and odor transfer | French Arrêté | Sensory evaluation
| Physical properties | Coating adhesion, corrosion resistance, seal integrity | NF standards | Physical testing
Test condition settings (Critical)
Test conditions must be determined based on the actual usage scenario of the can:
| Food type | Simulant | Temperature | Duration
| Acidic foods (tomatoes, fruits) | 3% Acetic acid | 121°C/2h or 100°C/2h | Simulated sterilization
| Alcoholic products (alcohol-preserved foods) | 10% Ethanol | Based on usage temperature | Based on duration
| Fatty foods (meat, fish) | Olive oil | Based on usage temperature | Based on duration
| Solid/dry foods | Distilled water | Based on usage temperature | Based on duration
French regulations place special emphasis on "simulating actual conditions of use"; there are subtle differences compared to EU testing, requiring the laboratory to be familiar with French practices. Step 5: Prepare French Technical Documentation
The following documents in French must be prepared for DGCCRF certification (this is the key difference from standard CE certification):
1. Product manual in French: Conditions of use, storage conditions, and warning statements
2. Labeling in French: Ingredients, shelf life, country of origin, and allergen information
3. Fiche MCDA (Compliance Dossier): Detailed listing of materials, ingredients, additives, and compliance with migration limits
4. Rapport d'essai (Test report in French)
5. Déclaration de conformité (Declaration of Conformity in French)
6. EU Declaration of Conformity (Bilingual: English/French)
7. Supply chain traceability documents: Information on suppliers of metal substrates, coatings, and inks
Step 6: French Customs Clearance and Registration
Submit the customs declaration and compliance documents to French Customs (Douane)
Some products require registration on the official DGCCRF website
Food contact materials also require registration with ANSES (French Agency for Food, Environmental and Occupational Health & Safety)
Customs and the DGCCRF may conduct random follow-up inspections
Step 7: Market Launch and Post-Market Surveillance
Products circulating in the French market are subject to random inspections by the DGCCRF
Failure to pass inspections may result in penalties such as product recalls, fines, or destruction of goods
Technical documentation must be retained for at least 10 years
II. Reference Timeline and Costs
| Item | Duration | Cost
| Testing Period | 5–7 working days
| Testing Cost | / | 1,000–3,000 RMB
Key Hazardous Substances of Concern
1. Bisphenol A (BPA): A highly controversial substance commonly found in internal coatings of metal cans; strictly regulated in France
2. BADGE/BFDGE: Key substances that migrate from epoxy resin coatings
3. Heavy metals: Migration of lead, cadmium, and nickel from can substrates
4. Aluminum migration: A specific concern for aluminum cans
5. Tin migration: A critical testing parameter for tin-plated cans
6. Phthalates: Substances potentially present in sealing gaskets and printing inks
7. Aromatic amines: Potential risk associated with aromatic epoxy coatings
8. Formaldehyde: Potential risks associated with phenolic resin coatings
Substances specifically banned in France
BADGE: Restricted for use under certain conditions
Certain aromatic amines: Subject to a specific list of banned substances under the *Arrêté du 25 novembre 1992*
Certain colorants and additives: Must comply with the French positive list
IV. Options for Handling Compliance
| Method | Target Audience
| Direct Laboratory Handling | Exporting enterprises with a local team in France
| French Certification Bodies | Recommended! Local bodies are familiar with DGCCRF requirements
| Cross-border Compliance Consultancies | Comprehensive service providers with teams in both China and France
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