Sale and labelling of food contact materials and articles

What must be indicated in the labelling of contact materials?

Contact materials made for consumer use must be labelled. In the case of contact material sold to food premises, it is enough if the labelling is in the documents. All materials themselves must have at least a traceability label.

Under Regulation (EU) 1935/2004, the mandatory labelling of contact materials sold to consumers includes:

  • The words 'for food contact or a specific indication as to their use;
  • If necessary, special instructions are to be observed for safe and appropriate use;
  • The name or trade name, and in either case, the address or registered office of the manufacturer, processor or seller responsible for placing on the market established within the Community;
  • Adequate labelling or identification to ensure traceability of the material or article;
  • In the case of active materials and articles, information on the permitted use or uses and other relevant information such as the name and quantity of substances released by the active component

What kind of labelling must be used in food contact materials for sale online?

If the online store is such that the consumer can also purchase contact materials there, these products must be labelled in accordance with Article 15 of Regulation (EU) 1935/2004. Since this is a consumer product, labelling must be in both Finnish and Swedish.  

Must the food contact material always be ready for use when sold or can the labelling require the consumer to rinse it, etc.?

Yes, the label can state that rinsing is required. Contact materials are always so-called machine clean and do necessarily as such meet all the purity criteria required for food contact.  The most important thing is guidance in how to use them correctly.

If the product is of metal, for example a metal strainer, that does not tolerate testing in a 4% acetic acid solution in accordance with Finnish national legislation, can the product be placed on the market by adding instructions that the product is suitable for only short-term contact with food with a pH of >4.5?

The intended use cannot be restricted if it involves the migration of heavy metal concentrations examined in accordance with Ministry of Trade and Industry Decision 268/1992. This is a national provision. The method in that decision is the method mentioned in Council Directive 84/300/EEC, where all samples are examined using 4% acetic acid and the sample must meet the requirements. The test conditions are therefore specified in a legal act and reflect the most unfavourable conditions under which all products must be tested.

Why do not all contact materials have a glass-and-fork symbol indicating their suitability for food contact?

The glass-and-fork symbol is a symbol appearing in Annex II to Framework Regulation (EU) 1935/2004 that can be used to indicate the use of a contact material for contact with food. Its use is voluntary and suitability for contact with food can also be stated in other ways, such as other similar symbols (coffee machine, wine bottle or soup spoon), by the text "for food contact", by naming the contact material according to its use, for example, by labelling. The way in which a material or article is for food contact has not been specified as long as the intended use is sufficiently well shown.

Page last updated 4/24/2019