Pet bowl US FDA food contact material testing process
Date：2025-12-03 09:31:19 Classification
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Pet bowls, as products that come into contact with pet food, must also meet the US FDA's safety standards for food contact materials to ensure they do not release harmful substances that could affect pets' health. The testing process is similar to that for human food contact tableware, but special attention must be paid to the safety of the materials used.
I. Core Regulatory Basis for Food Contact Materials by the US FDA
FDA testing of pet bowls primarily follows the relevant provisions of Title 21 of the Code of Federal Regulations (21 CFR), specifically including:
- Plastic materials: 21 CFR Part 177 (e.g., polymers such as PP, PE, and silicone)
- Metal/electroplated products: 21 CFR Part 175.300 (e.g., stainless steel and aluminum alloys)
- Ceramic/glass: FDA CPG 7117.06/07 (lead and cadmium leaching limits for glazes)
- Coatings/Adhesives: 21 CFR Part 175.300 (e.g., non-stick coatings and printing inks)
Key Note: In 2025, the FDA strengthened its oversight of materials containing PFAS (per- and polyfluoroalkyl substances). If pet bowls use waterproof and oil-resistant coatings, they must ensure that they do not contain these substances.
II. Complete Testing Process (Taking a Plastic Pet Bowl as an Example)
1. Document Preparation and Sample Submission
- Required Information: Product material composition table, manufacturing process description, color photos (with material parts labeled)
- Sample Requirements: 3-5 complete samples (must be consistent with mass production). Special parts (such as silicone anti-slip mats) must be provided separately.
2. Test Item Determination
Select corresponding tests based on the material. Common items include:
- Migration Test: Deionized water leaching, 8% alcohol leaching, n-heptane leaching (simulating different food types)
- Heavy Metal Detection: Leaching of lead, cadmium, mercury, etc. (key items for ceramic/metal materials)
- Composition Analysis: Screening for prohibited additives (such as bisphenol A, phthalates)
- Physical Properties: Temperature resistance (-40℃~120℃), impact resistance (simulating daily wear and tear)
3. Laboratory Testing (Approximately 5-7 working days)
- Authoritative Institution: Must be ISO certified 17025 Certified Third-Party Laboratories (e.g., Dezeway Testing, CNAS Registration No.: L8083)
- Testing Standards: Strictly adhere to FDA-mandated leaching conditions (temperature 70℃±2℃, immersion time 24 hours)
4. Report Issuance and Result Interpretation
- Acceptance Standards: Total migration < 0.5 mg/cm², heavy metal leaching < 0.1 mg/L
- Report Validity: The FDA does not issue "certificates of certification." Test reports must include laboratory qualifications, test methods, and specific values, serving as proof of customs clearance and market access.
5. US Agent and Subsequent Compliance
- Mandatory Requirement: Non-US companies must designate a US-based agent (responsible for receiving FDA inquiries).
- Record Retention: Test reports must be retained for at least 3 years. The FDA may conduct random checks of production records at any time.
III. Material Testing Items Reference (5-7 working days)
| Material Type | Key Test Items
| Plastics (PP/PE) | Solvent Leaching, Component Analysis
| Stainless Steel | Heavy metal leaching, coating adhesion
| Ceramics (with glaze) | Lead and cadmium migration, thermal shock resistance
| Silicone | Total extract, tear strength
Cost-saving tip: If multiple products of the same material have similar structures, apply for "series product testing," which can reduce costs by 30%~50%.
IV. Common Non-compliance Risks
1. Inferior plastic bowls: Use of recycled materials leads to excessive phthalates (EU REACH restrictions apply).
2. Ceramic glazes: Low-temperature firing leads to excessive lead leaching (FDA limit is 0.5μg/mL).
3. Silicone products: Addition of cheap vulcanizing agents leads to odor migration (affecting pets' appetite).
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