Food contact guide · Sources checked October 2026
Food contact supporting documentation, GMP and traceability records
Food contact supporting documentation is the evidence behind a declaration of compliance: Article 16 of assimilated Regulation (EC) No 1935/2004 says appropriate documentation must be available to demonstrate compliance and be made available to the competent authorities on demand, and for plastics, Article 16 of Regulation (EU) No 10/2011 says it contains the conditions and results of testing, calculations including modelling, other analysis, and evidence on safety or reasoning. The GMP regulation and the traceability rules add their own records.
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Food contact supporting documents: what the law asks for
The evidence behind a declaration
The GB text, paraphrased. Read the linked article for the full wording.
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| Point | What the GB text says | Source |
|---|---|---|
| Documentation must exist | Appropriate documentation must be available to demonstrate compliance, and made available to the competent authorities on demand | Regulation (EC) No 1935/2004, Article 16 (legislation.gov.uk), checked October 2026 |
| Plastics: who holds it | The business operator makes appropriate documentation available to the competent authorities on request, showing that plastic materials, intermediate products and substances comply | Regulation (EU) No 10/2011, Article 16 (legislation.gov.uk), checked October 2026 |
| Plastics: what it contains | The conditions and results of testing, calculations including modelling, other analysis, and evidence on safety or reasoning demonstrating compliance | Regulation (EU) No 10/2011, Article 16 (legislation.gov.uk), checked October 2026 |
| Testing methods | Rules for demonstrating compliance experimentally are set out in Chapter V of the plastics regulation, with simulants in Annex III and test conditions in Annex V | Regulation (EU) No 10/2011, Article 18 (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 GMP records
Good manufacturing practice: Regulation (EC) No 2023/2006
Article 3 of the framework regulation requires materials to be made under good manufacturing practice; the GMP regulation sets the systems and records.
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| Article | What the GB text says | Source |
|---|---|---|
| Quality assurance system | Establish, implement and keep to an effective, documented quality assurance system, proportionate to the size of the business, that considers staff, premises and equipment. Starting materials are selected against pre-set specifications, and operations follow pre-established instructions and procedures | Regulation (EC) No 2023/2006, Article 5 (legislation.gov.uk), checked October 2026 |
| Quality control system | Establish and maintain an effective quality control system that monitors whether GMP is implemented and achieved and identifies measures to correct failures. Corrective measures are taken without delay and made available to the competent authorities for inspections | Regulation (EC) No 2023/2006, Article 6 (legislation.gov.uk), checked October 2026 |
| Documentation | Keep appropriate documentation, on paper or electronically, on specifications, manufacturing formulae and processing relevant to compliance and safety, and records of the manufacturing operations and quality control results. Make them available to the competent authorities on request | Regulation (EC) No 2023/2006, Article 7 (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 traceability requirements
Traceability: Article 17 of Regulation (EC) No 1935/2004
On smaller screens, scroll the table sideways to see every column.
| Point | What the GB text says | Source |
|---|---|---|
| At all stages | Traceability of materials and articles is ensured at all stages to help control, recall of defective products, information to consumers and attribution of responsibility | Regulation (EC) No 1935/2004, Article 17 (legislation.gov.uk), checked October 2026 |
| Suppliers and customers | With due regard to technological feasibility, business operators have systems and procedures to identify the businesses that supplied them and those they supplied, and make that information available to the competent authorities on demand | Regulation (EC) No 1935/2004, Article 17 (legislation.gov.uk), checked October 2026 |
| Identifying the material | Materials and articles placed on the market are identifiable by an appropriate system that allows traceability by labelling or relevant documentation | Regulation (EC) No 1935/2004, Article 17 (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 compliance checklist
Food packaging compliance records: a practical list
A practical reading of the sources above, not a legal test or an official checklist. What you need depends on your materials and where you sit in the supply chain.
Business Companion lists assimilated Regulation (EC) No 2023/2006 on good manufacturing practice among the key legislation, and says enforcement officers may ask to see declarations (Business Companion: food contact materials, checked October 2026). The FSA’s page on the food contact materials regulations lists the 2012 Regulations for England, Wales and Northern Ireland, checked October 2026.
- Current, dated declarations of compliance for each material you buy or sell, with superseded versions kept and marked (what a declaration must contain).
- Specifications for starting materials, and evidence each delivery matched them.
- Migration test reports, calculations or modelling behind each declaration, with the conditions tested (migration test records).
- Your documented quality assurance procedures and the quality control results for each production run.
- Corrective actions taken when quality control found a problem, and when they were completed.
- Supplier and customer records that let you trace a batch one step back and one step forward.
- A record of which declaration, specification and test report applies to which batch.
Worked example (fictional)
Answering a request for supporting documentation
A fictional business and request, for illustration only.
1
The request
A food authority officer asks Example Packaging Ltd, a fictional tub maker, for the evidence behind its declaration for a chilled ready-meal tub.
2
Find the declaration
The quality lead pulls the current, dated declaration and the version it replaced, and checks which batches each one covers.
3
Gather the evidence
Behind it sit the resin supplier’s declaration, the migration test report for the finished tub with the simulants, time and temperature used, and a short written reasoning for why chilled storage is covered.
4
Show the GMP records
The team adds the specification for the resin, the quality control results for the batch in question and the one corrective action raised that month.
5
Trace the batch
Goods-in and despatch records show which resin lot went into the batch and which customers received it.
Food contact material documentation: related guides
Read next
The declaration, the evidence and the tools fit together.
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
What counts as supporting documentation for food contact materials?
For plastics, Article 16 of Regulation (EU) No 10/2011 says it contains the conditions and results of testing, calculations including modelling, other analysis, and evidence on safety or reasoning demonstrating compliance.
Do I have to send supporting documents to my customers?
The GB texts say documentation is made available to the competent authorities on request. What you share with customers is usually agreed between you; the declaration itself carries the information downstream operators need.
Do the GMP rules apply to small businesses?
Regulation (EC) No 2023/2006 says the quality assurance system should take account of the size of the business so it is not an excessive burden. The duty to keep documentation still applies.
How long should food contact records be kept?
The articles quoted on this page do not set a retention period. Article 5 of the framework regulation allows specific measures to set how long traceability records are kept. Ask your enforcement officer or adviser what applies to you.
Join the food contact waitlist
Leave your email and we will tell you when food contact declaration tracking opens. Nothing is on sale yet.