Food contact guide · Sources checked October 2026
Food contact declaration of compliance: what it must contain
A food contact declaration of compliance is a written statement that a material or article meets the rules that apply to it. In Great Britain, Article 16 of retained (now “assimilated”) Regulation (EC) No 1935/2004 requires one for materials covered by specific measures, and for plastics, Article 15 and Annex IV of assimilated Regulation (EU) No 10/2011 require it at every marketing stage other than retail and set what it must contain.
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Declaration of compliance food contact materials: the law in GB
Where the declaration comes from
The framework regulation sets the duty; the plastics regulation sets the content. Read the linked text for the full wording.
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| Point | What the GB text says | Source |
|---|---|---|
| The general duty | Materials covered by specific measures must be accompanied by a written declaration that they comply with the rules applicable to them, with appropriate documentation available to demonstrate it and made available to the competent authorities on demand | Regulation (EC) No 1935/2004, Article 16 (legislation.gov.uk), checked October 2026 |
| What every material must meet | Made under good manufacturing practice, and under normal or foreseeable use not transferring constituents in quantities that could endanger human health, bring an unacceptable change in the food’s composition, or a deterioration in its organoleptic characteristics (such as taste and smell) | Regulation (EC) No 1935/2004, Article 3 (legislation.gov.uk), checked October 2026 |
| Plastics: who issues it, and when | At marketing stages other than retail, a written declaration is available for plastic materials and articles, products from intermediate stages of manufacture and the substances intended for making them. It is issued by the business operator | Regulation (EU) No 10/2011, Article 15 (legislation.gov.uk), checked October 2026 |
| Plastics: renewal | The declaration must identify what it covers, and be renewed when substantial changes in composition or production change migration, or when new scientific data becomes available | Regulation (EU) No 10/2011, Article 15 (legislation.gov.uk), checked October 2026 |
| Who applies the law in GB | The FSA says all food contact materials must comply with assimilated Regulation 1935/2004. Plastics Regulation 10/2011 became part of GB’s retained law, and the 2012 Materials and Articles in Contact with Food Regulations set offences and enforcement in England | FSA authorisation guidance and FSA review of the 2012 Regulations, checked October 2026 |
Sources checked October 2026. Legislation and guidance change: open the linked source before relying on any row. This page is general information about the position in Great Britain, not legal or regulatory advice; your enforcement officer, your customers and your own technical advisers decide what applies to your materials.
Plastic food contact declaration of compliance: Annex IV
What a plastics declaration must contain
The nine points of Annex IV to Regulation (EU) No 10/2011, paraphrased. legislation.gov.uk shows point 6 was amended in GB from 1 April 2025 by S.I. 2025/361.
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| Annex IV point | What it requires (paraphrased) | Source |
|---|---|---|
| 1 and 2: who | The identity and address of the business operator issuing the declaration, and of the operator who manufactures or imports the material, article, intermediate product or substance | Regulation (EU) No 10/2011, Annex IV (legislation.gov.uk), checked October 2026 |
| 3 and 4: what and when | The identity of the materials, articles, intermediate products or substances, and the date of the declaration | Regulation (EU) No 10/2011, Annex IV (legislation.gov.uk), checked October 2026 |
| 5: the compliance statement | Confirmation that they meet Regulation 10/2011 and Articles 3, 11(5), 15 and 17 of Regulation (EC) No 1935/2004 | Regulation (EU) No 10/2011, Annex IV (legislation.gov.uk), checked October 2026 |
| 6 and 7: substance information | Adequate information on restricted substances used, and on substances that are also subject to restrictions in food (including specific migration levels from experimental data or calculation), so downstream operators can comply | Regulation (EU) No 10/2011, Annex IV (legislation.gov.uk), checked October 2026 |
| 8: specifications on use | The types of food it is intended to contact, the time and temperature of treatment and storage, and the highest ratio of food contact surface area to volume for which compliance was verified | Regulation (EU) No 10/2011, Annex IV (legislation.gov.uk), checked October 2026 |
| 9: functional barriers | Where a functional barrier is used in a multi-layer material or article, confirmation that it meets the relevant requirements of Articles 13 or 14 | Regulation (EU) No 10/2011, Annex IV (legislation.gov.uk), checked October 2026 |
Sources checked October 2026. Legislation and guidance change: open the linked source before relying on any row. This page is general information about the position in Great Britain, not legal or regulatory advice; your enforcement officer, your customers and your own technical advisers decide what applies to your materials.
Food contact declaration of compliance template
Checking a declaration you receive
A practical reading of Annex IV, not an official template. No GB form was found on the pages we checked, and the regulation sets content, not layout.
Business Companion, the Trading Standards guidance site, says to ask your packaging supplier for a declaration and keep it with your records, because Trading Standards or Environmental Health officers may ask to see it (Business Companion: food contact materials, England and Wales, checked October 2026). For the evidence behind the declaration, read food contact supporting documentation.
- It names the issuing business and the manufacturer or importer, with addresses.
- It identifies the exact material or article you buy, by name, grade or code, not a product family you are unsure of.
- It is dated, and the date is after the last change you know of to the material.
- It confirms compliance with the plastics regulation and the framework regulation, and says which version of the rules it assessed against.
- It states the food types, time and temperature of use, and the surface area to volume ratio, and these match how you will use it.
- It lists restricted substances, or substances also restricted in food, that you need to know about.
- It says whether a functional barrier is relied on.
Worked example (fictional)
One declaration down the supply chain
A fictional supply chain, for illustration only. It is not advice on what your materials need.
1
Resin supplier
Example Polymers Ltd, a fictional business, supplies polypropylene granules to a moulder with a declaration that lists the substances with specific migration limits a downstream user needs to know about.
2
Converter
Example Packaging Ltd moulds the granules into lidded tubs. It relies on the resin declaration, adds its own migration testing for the finished tub, and issues its own declaration naming the tub, the food types (chilled ready meals) and the time and temperature it was tested for.
3
Food business
Example Kitchen Ltd, which fills the tubs, checks the declaration covers chilled storage and microwave reheating, the way its customers will use the tub. It finds reheating is not covered and asks the converter before it goes on sale.
4
Change
Six months later the converter changes colourant. It reviews whether migration changes and issues a renewed, dated declaration; the food business files it and marks the old one as superseded.
Food packaging declaration of compliance: related guides
Read next
A declaration is only as good as the evidence behind it.
Read what supporting documentation should hold and how migration test records work. If you are choosing a tool, see food contact compliance software compared.
Northern Ireland is different
The rows on this page describe the assimilated texts that apply in Great Britain. Some EU food contact rules apply in Northern Ireland under the Windsor Framework: for example, the FSA says Commission Regulation (EU) 2022/1616 on recycled plastic applies in Northern Ireland and not in Great Britain (FSA authorisation guidance, checked October 2026). If you supply Northern Ireland or the EU, read the EU text of Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011 on EUR-Lex, which may have been amended since 2020. In Scotland, read the Food Standards Scotland guidance.
Food contact tracking is not available yet
Soteriaa is building food contact declaration tracking; join the waitlist. It is not available yet, and it will not test materials, write or sign a declaration, or confirm that anything complies. Join the food contact waitlist to hear when it opens.
FAQ
Common questions
Is a declaration of compliance a legal requirement in the UK?
In Great Britain, Article 16 of assimilated Regulation (EC) No 1935/2004 requires a written declaration for materials covered by specific measures, and plastics Regulation (EU) No 10/2011 requires one at marketing stages other than retail. Whether your material is covered depends on what it is; check the legislation or ask your enforcement officer.
Who issues the declaration of compliance?
For plastics, the business operator at each marketing stage other than retail issues it, and it names both the issuer and the manufacturer or importer. Each business passes information down the chain so the next one can comply.
How often must a declaration be renewed?
Regulation 10/2011 does not set a fixed period. It says the declaration is renewed when substantial changes in composition or production change migration, or when new scientific data becomes available.
Is there an official template?
Not one this page found for Great Britain. Annex IV of Regulation 10/2011 sets what a plastics declaration must contain, not its layout.
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