When it comes to food safety, the materials used in tools that come into contact with food must meet strict regulatory standards. In the United States, the FDA's regulations under CFR21 110 Subpart C emphasize that food-contact surfaces should be corrosion-resistant and composed of non-toxic materials. While there's no explicit requirement to test finished products, it's common practice to provide documentation proving the base materials of these tools are FDA-compliant.

However, businesses operating in Europe face a more rigorous set of legal obligations. Under Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011, every food contact material must undergo migration testing to ensure it is safe for food use. This process involves assessing how much of a substance, potentially harmful chemicals, could migrate from the tool's material to the food being processed.

Migration tests are critical because they determine the maximum permitted levels of migration, which vary depending on the type of food and conditions of use. For instance, the overall migration limit is typically 10 mg/dm², but this threshold changes when dealing with infant foods or volatile substances. Specific migration limits are also assessed based on the individual substances involved, requiring careful review against the relevant tables in Annex I of the regulation.

Documentation Requirements

A compliant declaration of compliance must include several key pieces of information. First, the declaration should clearly identify both the issuing business and the manufacturer. It must list all materials used in the product and confirm their compliance with EU regulations. Additionally, migration test results must be included, along with details about the types of food the tool is intended for and the temperature/time conditions it can safely endure.

For example, if you have two different colored versions of the same tool, each would require its own documentation since the addition of dyes alters the material composition. A single document covering multiple products is only acceptable if they are made from identical materials.

This documentation serves as essential guidance for food processors to ensure safe usage within their facilities. Although not mandated by the FDA, such documentation can significantly strengthen food safety protocols.

If you're sourcing tools, always request these documents directly from the manufacturer. Ensure each document corresponds specifically to the material it describes, as a generic document won't suffice under EU law. At Remco Products, we assist our customers by providing these documents upon request. Feel free to reach out to our customer service team for assistance.

In summary, maintaining transparency through proper documentation ensures compliance and enhances consumer trust. By adhering to these guidelines, manufacturers can contribute to safer food processing environments worldwide.

For further reading, refer to Regulation (EU) No 10/2011 – Annex IV, which provides detailed instructions regarding declarations of compliance.