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Declaration of Compliance (DOC) for Food Contact Materials

By Little Pro on 2017-03-01 Views:  Update:2017-03-15

EU's food contact legislation has set out mandatory requirement that business operators provide written declaration of compliance (DOC) for some types of food contact materials (i.e, plastics). China has similar requirements on DOC for food contact materials and containers. In this article, we will provide a summary of basic requirements on the declaration of compliance (DOC). Sample declaration of compliance (DOC) will be given in the end of this article. 

Who Should Provide Declaration of Compliance (DOC)?

Firstly, you need to know which food contact materials require the declaration of compliance (DOC) and who should provide the declaration of compliance. In EU, the DOC is mandatory for food contact plastics (including recycled plastics), active and intelligent materials, ceramics and regenerated cellulose film.  For other types of food contact materials (i.e, paper, inks), DOC is not mandatory at the moment. 

The EU plastics regulation further requires that a written declaration of compliance (DoC) be provided for finished plastic materials and articles, products from intermediate stages of their manufacturing as well as for the substances intended for the manufacturing of those materials and articles (excluding retail stage).

Each manufacturer has to declare their compliance under his responsibility depending on his role in the supply chain and communicate his DoC to customers (see below example).

  • Producer of a monomer or additive:  Ensuring that the substance is authorised for use and complies with the restriction and specifications listed in the Union list. 
  • Producer of an intermediate plastic product:  Ensuring that  all monomers and additives are authorised and indicating the conditions of use under which migration limits can be complied with.
  • Manufacturer of final food contact material or article: Indicating the conditions of use under which restrictions and migration limits can be complied with. Usually migration testing is done on finished food contact materials and articles to verify compliance. 

Requirements on Declaration of Compliance (DoC)

The plastics regulation further requires that the written declaration of compliance for food contact materials contain the following information. They can be modified for use for other types of food contact materials as well.

  • the identity and address of the business operator issuing the DoC;
  • the identity and address of the manufacturer or importer;
  • the identity of the food contact materials, intermediate product or substance;
  • the date of the declaration;
  • confirmation that the plastic materials or articles, products from intermediate stages of manufacture or the substances meet relevant requirements laid down in EU's framework regulation;
  • information about the compliance of substances subject to any restriction or specification;
  • specifications on the use of the material or article, such as: (i) type or types of food with which it is intended to be put in contact; (ii) time and temperature of treatment and storage in contact with the food; (iii) ratio of food contact surface area to volume used to establish the compliance of the material or article;
  • when a functional barrier is used in a multi-layer material or article, the confirmation that the material or article complies with the requirements of Article 13(2), (3) and (4) or Article 14(2) and (3) of this Regulation.

Sample Declaration of Compliance (DoC) for Food Contact Materials

The picture below is a sample of declaration of compliance (DoC) for plastic food contact materials given by the Food Safety Authority of Ireland and it has included all required info. Click here to download the sample DoC template in pdf format. The template can be easily modified for use for other types of food contact materials. 

sample declaration of compliance food contact materials

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How to comply with food contact regulations in EU

 

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