DGCCRF Certification Report Guidelines for Composite Film Bags
Date：2026-06-16 09:30:43 Classification
：【question】 Visits：
Multi-layer Film Pouch Certification Report Guidelines
Multi-layer film pouches, as a common form of food packaging, must comply with DGCCRF (French Directorate General for Competition, Consumer Affairs and Fraud Control) regulations and the EU EC 1935/2004 framework requirements when exported to the French market. This guide systematically outlines the key points of the entire certification process.
I. Applicable Regulations and Standards
EU Regulation EC 1935/2004: General Framework for Food Contact Materials, specifying general requirements
EU Regulation EU 10/2011: Specific Requirements for Plastic Materials and Articles (involving total migration and specific migration)
French Decree Décret n°2007-766 and its supporting decrees: FCM compliance requirements in France
EU Regulation EC 2023/2006: Good Manufacturing Practice (GMP) requirements
EU Regulation (EU) 2018/213: Bisphenol A (BPA) limit requirements
II. Core Testing Items
Composite film bags need to be evaluated separately for each layer material. The main testing dimensions are as follows:
| Test Category | Specific Item | Applicable Material
| Total Migration Test | Total migration amount after immersion in simulated liquid (limit of 10 mg/dm²) | Plastic layer, ink layer
| Specific Migration | Primary aromatic amines (PAA), heavy metals (lead, cadmium, etc.), plasticizers, vinyl chloride monomer, etc. | Inks, Adhesives, Plastic Substrates
| Sensory Testing | Odor/Color Transfer (Penetration Test) | Overall Packaging
| Specific Substances | Bisphenol A, Photoinitiators, Antioxidants, Benzene Solvent Residue | Depends on Formulation
| Microbiological Testing (Optional) | Specific Scenario Requirements | Food Grade Requirements
⚠️ Key Point: Composite film bags typically contain a printing layer + barrier layer + heat-sealing layer + adhesive. Each layer requires independent evaluation, and MSDS for the raw materials and inks of each layer must be provided.
III. Required Documents List
The following technical documents are required before submission for testing:
1. Product Structure Description: Layered structure diagram (indicating the material, thickness, and substrate of each layer)
2. Bill of Materials (BOM): Resin grade, ink type, and adhesive type for each layer
3. Ink/Adhesive MSDS: Especially information on aromatic amines, heavy metals, and phthalates
4. Process Description: Printing method, lamination process, and curing conditions
5. Product Specifications: Operating temperature range and food contact type (acidic/alcoholic/fatty)
6. Client and Manufacturer Information
IV. Testing Process and Cycle
Phase One: Initial Communication (1-2 days)
The laboratory confirms the test plan and selection of the simulation solution based on the material composition (common simulation solutions: 10% ethanol, 3% acetic acid, olive oil substitute, etc.).
Phase Two: Sample Preparation (Client Responsible)
Sample Quantity: Recommended at least 6-10 complete packaging bags (depending on specifications and dimensions)
Packaging bags must be pre-laminated and printed finished products; single films are not accepted.
Phase Three: Laboratory Testing (5-7 working days)
Migration testing typically requires conditions such as 40°C/10 days or 70°C/2 hours.
Overall cycle (including rectification) is typically 20-30 working days.
Phase Four: Report and Certificate (3-5 days)
Laboratory issues test report in English/French.
Based on the report, a Declaration of Compliance (DoC) and GMP Declaration are issued.
V. Cost Reference
| Item | Cost Range (USD) | Remarks
| Full set of migration tests (3-4 types of simulants) | 800 - 2000 | Includes PAA and heavy metals
Cost-saving suggestion: If ink and adhesive suppliers can provide products compliant with EU 10/2011... The statement claims that this can significantly reduce the number of tests required.
VI. Labeling and Packaging Compliance Requirements
Composite film bags sold in France must meet the following labeling requirements:
**Apte au contact alimentaire (Suitable for food contact)** or equivalent in English/German
**Knife/Wine Glass Marking** (Strongly recommended for easy customs identification)
**Temperature Range Marking** (e.g., "Suitable for Microwave Heating", "Suitable for Freezing")
**Manufacturer/Packaging Company Information (Address of Responsible Party within Europe)**
**Batch Traceability Code**
VII. Amazon France Compliance Key Points
Required Materials from Amazon:
1. DGCCRF Compliance Test Report (including reference to EU 1935/2004)
2. Declaration of Compliance (DoC): Includes a list of regulations, product liability party information, and signatory
3. GMP Declaration: Good Manufacturing Practice (GMP) compliance at the production plant
4. Product Images: Includes detailed label images and inner bag structure diagrams
5. If applicable: Compliance declaration from ink/adhesive suppliers
Common Reasons for Removal: Report does not cite EU 1935/2004; Lack of GMP Disclaimer: The simulated liquid selection is inconsistent with actual usage scenarios; the ink layer was not evaluated separately.
VIII. Practical Recommendations
1. Ink Selection: Prioritize the use of environmentally friendly inks that are benzene-free and low in aromatic amines to avoid compliance risks.
2. Adhesive Control: Choose alcohol-soluble or water-based adhesives with no PAA risk for composite adhesives.
3. Structural Optimization: Place the printed layer inside the outermost or intermediate barrier layer to prevent direct contact between ink and food.
4. Series Certification Strategy: Multiple specifications of products with the same structure, ink, and adhesive can apply for "series reports."
5. Record Keeping: Retain all raw material purchase vouchers and test reports for at least 5 years for customs inspection.
Shen Gongwang Security: 44030602006947