Food Contact Compliance for the EU and UK

A spring-mounted pull-out tap standing on a brushed stainless deck, a deep bowl with its drain below, and two stainless shelves holding glasses and a glass bottle behind. — A welded bowl in use. Under EU and UK food-contact rules the requirement is smooth, impervious and cleanable, and the argument is always about where two surfaces meet.

01What 1935/2004 requires

The framework regulation requires that food contact materials do not transfer constituents to food in quantities that could endanger health, change the composition of the food unacceptably, or deteriorate its taste and odour. It applies to every material in the chain, including the metal.

For stainless steel the practical evidence is: the alloy grade, a mill certificate showing the heat, and a declaration that the material is suitable for food contact under the intended conditions. Note the phrase intended conditions — a top that will hold tomato sauce at 80 °C overnight is a different question from one that holds dry flour.

02What 2023/2006 adds

Good manufacturing practice is the part that catches fabricators rather than mills. It requires that materials are produced to a quality system, that processes which could affect the finished article are controlled, and that documentation allows traceability.

For a countertop that means the fabrication steps are in scope, not just the plate: welding, graining, and anything applied to the surface. A passivation treatment is a process step that should be recorded, because it is the step that restores the surface that makes the material suitable in the first place.

Traceability starts at the heat number

The heat number on the mill certificate is what links your countertop to the plate it was cut from. If a document set does not let you follow that line, it is decoration.

03The UK position

The UK retains equivalent requirements through assimilated legislation, so the substance of the obligation is the same as the EU. The difference is administrative: the instrument is separate, and a declaration written only against the EU regulation may not be accepted without amendment.

If your customer is in the UK and asks for a declaration, say so on the enquiry so the wording is right the first time.

04What we supply

Fig. 1 — Four documents, in this order. A countertop is a food contact article, not a machine, so CE marking does not apply to it.

The document set is agreed on the quotation. Typically: mill certificate with heat number, inspection sheet, packing list, and — where the order calls for it — a declaration of conformity covering the material and the fabrication steps we perform.

What we will not do is describe a test we have not run, or issue a certificate under a scheme we are not accredited for. If your customer needs a migration test on the finished article, that is arranged on your side and we will supply the material evidence it depends on.

The material evidence itself is four numbers: the grade, 304 (1.4301) or 316L (1.4404); the thickness, 5 to 10 mm; the mill certificate to EN 10204 3.1 with the heat number; and the fabrication record showing the weld was pickled and passivated. The ±0.05 mm edge tolerance is a dimensional figure rather than a compliance one, but it appears on the same inspection sheet and it is the number a buyer usually asks about first.

On timing, one point that catches European buyers: our lead time is 15 working days from a confirmed drawing, and a declaration worded for a specific member state can take longer to agree than the parts take to make. Send the wording question with the enquiry, and it is resolved before the plate is cut. Parts are packed for sea freight with edges protected, and they ship with the inspection sheet and packing list in the case.

Compliance overview · Australia and NZ · Warranty and its limits · Order terms