French DGCCRF certification process for food packaging bags
Date：2026-03-04 09:27:34 Classification
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The core of obtaining compliance with the French DGCCRF (Note: DGCCRF is a regulatory body, not a certification body; therefore, the accurate term is "testing and declaration of compliance with DGCCRF regulations") for food packaging bags is proving that chemicals in the packaging materials will not migrate into food and thus harm human health.
France has stricter regulations for food contact materials (FCMs) than the general EU standards, with its own independent national legislation. The following are the detailed application process, key testing items, and precautions:
I. Core Application Process
1. Clarify Product Material and Intended Use
Before submitting for testing, the following information must be clarified, as the testing standards vary significantly depending on the material:
Material Type: Plastics (PE, PP, PET, PA, etc.), Paper/Cardboard, Aluminum Foil, Composite Materials, Biodegradable Materials, etc.
Food Contact Type: Water-based, Acidic, Oily, Alcoholic, Dry Powder, etc. (This determines the food simulant used in the test).
Usage Conditions: Room temperature, refrigeration, freezing, microwave heating, high-temperature filling, etc. (This determines the test temperature and time).
2. Choosing a Qualified Laboratory
Requirements: A third-party laboratory with ISO 17025 accreditation and familiarity with specific French regulations must be selected.
Recommended Institution: DEZEW Testing CNAS Registration No.: L8083
Key Point: Clearly state to the laboratory that the objective is "export to France, requiring compliance with DGCCRF requirements," not just EU 10/2011.
3. Sending Samples and Developing a Testing Plan
Sample Quantity: A sufficient number of finished bags are typically required (e.g., 20-50, depending on the number of tests) for cutting and migration testing.
Test Plan Confirmation: The laboratory will develop a testing plan based on your materials and intended use, referencing the relevant French regulations.
4. Laboratory Testing (Core Component)
Mainly involves total migration and specific migration tests:
Total Migration: Tests the total amount of all non-volatile substances migrating into the food simulant.
Specific Migration: Quantitative analysis of specific hazardous substances (such as heavy metals, plasticizers, primary aromatic amines, etc.).
Sensory Testing: Checking for off-odors or color transfer.
5. Issuance of Reports and Signing of Declaration of Conformity (DoC)
Test Report: The laboratory issues a report in English or French, showing whether all data are below the limits stipulated by French regulations.
Declaration of Conformity (DoC): This is the most crucial document. Based on the test report, the manufacturer or EU importer must sign a French version of the DoC, declaring that the product complies with the relevant DGCCRF regulations.
Note: DGCCRF officials will primarily review this DoC and the supporting test report during inspections.
II. Key Testing Items (Classified by Material)
French regulations have specific legal restrictions on different materials. The following are the mandatory tests for common food bags:
1. Plastic Bags
Applicable Regulations: EU No. 10/2011 + French Supplementary Requirements.
Core Tests:
Total Migration: Using simulants such as olive oil, ethanol, and acetic acid.
Specific Migration:
Heavy Metals: Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent Chromium (CrVI).
Plasticizers: Phthalate (6P, 16P, 24P).
Antioxidants/Stabilizers: BHT, Irganox, etc.
Monomer Residues: Such as vinyl chloride, acrylonitrile, etc.
High Concern: For color-printed bags, primary aromatic amines (PAAs) in the ink must also be tested.
2. Paper/Cardboard Bags
Applicable Regulations: French Arrêté du 9 novembre 1994 (Very strict, specific to France).
Core Tests:
Heavy Metals: Lead, Cadmium, Mercury, Arsenic, Antimony, Barium, Cobalt, Copper, Zinc, etc. (France lists more elements than the EU).
Formaldehyde, Bisphenol A (BPA).
Fluorescent whitening agents.
Mineral oil residue (MOSH/MOAH): Derived from recycled paper or ink; France has very strict regulations on this.
Microbiological indicators: Sometimes required.
3. Composite films/aluminum-plastic bags
Must meet the requirements for both the plastic layer and the adhesive layer. The focus is on testing for solvent residue and migrations in the adhesive.
III. Required Compliance Documentation Package
To prepare for DGCCRF market inspections or customs checks, you must prepare the following documents in French:
Declaration of Conformity (DoC):
Must be written in French.
Includes: Manufacturer information, product name/model, material description, list of compliant regulations (down to the French decree number), testing conditions, signatory and date.
Third-party test report:
Serving as technical support for the DoC, it must be recently valid (usually recommended to be within 1-2 years).
Labeling:
The product or packaging must bear the "glass and fork" symbol (Food Safe Symbol).
If for a specific purpose (e.g., "for chilled drinks only"), it must be labeled in French.
A traceability batch number must be included.
The name and address of the EU responsible person/importer must be included.
IV. Timeframe and Cost Reference
Timeframe:
Routine testing: 5-7 working days.
If complex mineral oil (MOSH/MOAH) or full scans are involved, it may take 7-10 working days.
Cost:
Plastic materials: Approximately 1500 - 2000 RMB (depending on the number of simulants and the scope of specific substance screening).
Paper materials (France-specific): Approximately 2000 - 3000 RMB (higher cost due to higher heavy metal content and mineral oil testing).
Note: Specific prices depend on the laboratory and the number of tests.
V. Pitfall Avoidance Guidelines and Special Notes
**French-Specific "Arrêté du 9 novembre 1994":**
Many sellers only perform the EU-standard BfR (Germany) or AP (Italy) tests, which are insufficient in France. France has very specific requirements for heavy metal limits and mineral oils in paper products; ensure your report cites the relevant French law.
**Ink and Glue Risks:**
If inferior inks are used on the printed patterns on food bags, they are highly susceptible to migration. It is recommended to request ink suppliers to provide a declaration of compliance with EuPIA (European Ink Association) standards and to test the migration levels on the finished bags separately.
**Language Pitfalls:**
DoC and labels must be in French. English documents may be considered non-compliant during spot checks in the French market, leading to product removal.
**Amazon France Requirements:**
If you sell on Amazon, the backend may require you to upload FCM compliance documents. Ensure you upload a complete report containing test data and a French DoC, not just a certificate.
Regular updates:
If the formulation changes (e.g., different ink or resin supplier), retesting is required.
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