A declaration of compliance is the document in which the manufacturer or supplier of a food contact material states, in writing, that the material complies with the rules that apply to it and specifies the conditions under which that is true. For plastic materials and articles it is not optional: Commission Regulation (EU) No 10/2011 requires it at each marketing stage other than retail, and Annex IV to that regulation sets out what it has to contain.
What it has to say
- The identity and address of the business issuing it, and of the manufacturer of the material.
- The identity of the material or article, including the structure where it is a laminate.
- The date of the declaration.
- Confirmation of compliance with the relevant requirements, including Regulation (EC) No 1935/2004 as the framework and Regulation (EU) No 10/2011 for plastic layers.
- Information on substances subject to a restriction, so the customer downstream can apply it.
- Specifications on use: the food types it is intended for, the time and temperature of contact, and the ratio of contact surface to food volume used to establish compliance.
Why the use conditions matter more than the certificate
A declaration is only valid for the conditions it names. One written for dry ambient foods does not cover an acidic wet product, and one written for short contact at chilled temperature does not cover twenty-four months at minus eighteen degrees. Buyers routinely file a declaration without reading the conditions and later find it does not cover the application at all.
Supporting documentation, including migration test results, sits with the supplier and has to be made available to a competent authority on request. Ask whether it exists before you need it.
The wider documentary chain, including good manufacturing practice under Regulation (EC) No 2023/2006 and the position of non-plastic materials, is set out in the food contact materials guide. Vorezan is an information platform, not a certifier or a laboratory; confirm the current text of the regulations in the Official Journal.
