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Food Packaging French DGCCRF Certification Test Report

Date:2026-02-06 09:59:12 Classification :【question】 Visits:
The DGCCRF is a regulatory body that requires food packaging materials to comply with EU regulations. Evidence of compliance includes migration test reports and other relevant documents issued by compliant laboratories.

1. Regulatory Framework (The Laws You Need to Comply With)

Food packaging materials in the EU/France are primarily governed by the following regulations:

Framework Regulation (EC) No 1935/2004: This is the general framework, requiring all food contact materials to be safe, not to transfer their components into food posing a threat to human health, not to cause unacceptable changes in food composition, or to cause deterioration of sensory properties.

Good Manufacturing Practice Regulation (EC) No 2023/2006: Requires quality control during the production process.

Specific Measures Regulation: Specific regulations apply to different materials. For example, for plastics: (EU) No 10/2011 is the most important regulation. It has a Union List of permitted monomers and additives and specifies limits for overall migration and specific migrations. Recycled plastics, ceramics, active and smart materials also have corresponding regulations.

2. What exactly does a “test report” refer to?

To demonstrate compliance, you typically need to commission an accredited third-party laboratory to conduct tests, primarily generating the following two types of reports:

a) Migration Test Report (Core Document)

Overall Migration: Tests the total amount of all non-volatile substances migrating from packaging materials into food. The limit is 10 mg/dm² or 60 mg/kg of food.

Specific Migration: Tests the migration amount of a specific hazardous substance (such as heavy metals, plasticizers, monomers). For example, lead, cadmium, formaldehyde, and bisphenol A all have strict limits.

Testing Conditions: The laboratory will select the most stringent simulant solution for testing based on the type of food you are packaging (acidic, alcoholic, oily, etc.), contact temperature, and contact time.

b) Ingredient Screening/Declaration of Conformity Support Report

Verifies that all substances used in the packaging materials (especially plastics) are on the EU's permitted use list.

This may include screening tests for certain prohibited or restricted substances.

3. Complete Compliance Documentation Package (Required for DGCCRF Inspection)

Test reports alone are insufficient; you need to prepare a complete set of technical documentation, typically including:

1. Declaration of Conformity: A formal document issued by the manufacturer or importer declaring that the product complies with EU regulations. This is a legally mandatory document.

2. Supporting Documents: Migration test reports (as described above). Material Specifications: Detailed description of each layer's structure, composition, and supplier information. Good Manufacturing Practice (GMP) Declaration. Supplier-provided declarations of conformity and test reports (e.g., inks, adhesives, masterbatches, etc.). Labels and Instructions (ensuring their content is compliant).

3. Product Labeling: While not as mandatory as cosmetics for all information on packaging, traceability information (e.g., manufacturer, batch number) must be ensured, and instructions for use (e.g., "microwave safe") must not be misleading.

4. Important Reminders and Recommendations

Responsible Parties: Importers or distributors selling the product in the EU market bear primary responsibility for ensuring product compliance. They must be able to obtain all compliance documentation from you (the manufacturer).

Laboratory Selection: Always choose a laboratory that is ISO 17025 certified and qualified to test food contact materials (DEZEW Testing CNAS Registration No.: L8083). Their reports are more credible.

Assessment Before Testing: Before submitting your product for testing, communicate with the laboratory or consulting agency to design a testing plan based on your packaging materials (plastic, paper, composite materials), processing technology (printing, coating), and intended use (what food will be contained, will it be heated?). Avoid unnecessary testing items.

French Labeling: Mandatory labeling information for all products intended for French consumers must be in French.

Your compliance path should be as follows:

Determine packaging materials and intended use → Conduct a compliance assessment against EU regulations (e.g., (EU) 10/2011) →

Design a testing plan → Submit samples to an accredited laboratory for migration testing →

Obtain the test report → Draft and sign a declaration of conformity → Compile complete technical documentation →

Ensure product labeling compliance → Launch the product and be prepared for DGCCRF spot checks.

Therefore, when your customers or partners request a "DGCCRF certification test report," what they actually need is:

"A migration test report and a complete set of technical documents issued by an accredited laboratory, proving that the food packaging complies with EU (EC) No 1935/2004 and (EU) No 10/2011 regulations."

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