FRANCE FOOD CONTACT MATERIALS COMPLIANCE SERVICES
Manufacturers and suppliers of PP, PET and other plastic resins, rubber, silicone elastomers, coatings, printing inks, additives, metals and other intermediate materials intended for downstream food-contact applications in France need to address both harmonized EU food contact requirements and any applicable French national measures. For non-harmonized materials, or materials subject to additional French provisions, a general EU test report alone may not provide sufficient evidence for the intended French use.
REACH24H primarily supports raw material and intermediate material manufacturers, suppliers and exporters. Based on material composition, intended downstream use, food-contact conditions and available supply-chain evidence, we provide Declaration of Compliance (DoC) preparation, French national new-substance application support for rubber or silicone elastomer food-contact materials, testing strategy and oversight, substance status reports, customized training, regulatory translation and consulting.
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France FCM Compliance at a Glance
| Item | Key Information |
|---|---|
| Target market | France |
| Primary clients | Manufacturers, suppliers and exporters of food-contact raw materials and intermediate materials |
| Key materials | PP, PET and other resins; rubber; silicone elastomers; additives; coatings; printing inks; adhesives; metals; paper and board |
| Regulatory layers | Applicable EU FCM legislation plus French national measures and material-specific requirements |
| Key authorities and resources | DGCCRF for enforcement and national regulatory administration; ANSES for scientific health risk assessment of national adaptation requests |
| Core support | Substance status review, testing strategy and oversight, DoC, new-substance support for rubber or silicone elastomer FCMs, customized training, regulatory translation and consulting |
| Key compliance question | Does the available evidence support the material's intended downstream food-contact use in France? |
Why EU Compliance Alone May Not Be Enough for France
France is an EU Member State. Regulation (EC) No 1935/2004, Regulation (EC) No 2023/2006 on good manufacturing practice, and applicable EU-specific measures all apply in the French market. For plastic food-contact materials, Regulation (EU) No 10/2011 sets rules for authorized substances, restrictions, migration limits, testing and supply-chain documentation.
However, the EU has not adopted complete, harmonized specific measures for every material category. France therefore maintains national measures and the French Directorate-General for Competition Policy, Consumer Affairs and Fraud Control (DGCCRF) publishes material-specific food-contact suitability resources. Companies should first identify the applicable EU requirements and then determine whether French national rules or additional assessment criteria apply to the material and its intended use.
The term “DGCCRF certification” is commonly used in the market, but DGCCRF does not issue a single, standardized certification for all food-contact materials. Compliance is generally demonstrated through the correct legal assessment, composition and substance review, appropriate testing, a DoC where applicable, and supporting technical documentation.
Who Needs France Food Contact Compliance Support?
Plastic resin and polymer manufacturers: Producers of PP, PET and other resins or intermediate materials intended for downstream food packaging, containers or other food-contact applications.
Rubber and silicone elastomer suppliers: Suppliers of base polymers, rubber compounds, silicone elastomer materials and other intermediates intended for food-contact components.
Additive and functional material suppliers: Companies supplying additives, colorants, coatings, printing inks, adhesives or other substances and materials to food-contact material manufacturers.
Metal, paper and board material companies: Manufacturers and exporters supplying materials for food packaging, processing equipment or other food-contact applications in France.
Downstream article manufacturers, importers and traders: Companies that need to review upstream material evidence, respond to customer questions or confirm whether a material is suitable for a specific French use.
For suppliers placing resins, compounds, additives or other intermediate materials on the market, a material name alone is not enough to establish compliance. The assessment should consider composition, applicable restrictions, intended downstream use and processing conditions, and should define the DoC, testing rationale and other evidence that the supplier needs to provide.
French Food Contact Materials Regulatory Framework
France FCM compliance is not a choice between “EU testing” and “DGCCRF testing.” The correct approach depends on the material composition, intended downstream application, food type, contact time and temperature, repeat-use conditions, and the position of the material in the final structure.
| Regulatory Layer / Source | Main Scope | What Material Suppliers Should Check |
|---|---|---|
| EU general framework | Regulation (EC) No 1935/2004: general safety, inertness, labelling and traceability principles, with a framework for specific measures. | Confirm that the material or article is within scope and that safety and supply-chain evidence support the intended use. |
| EU GMP requirements | Regulation (EC) No 2023/2006: good manufacturing practice for food-contact materials and articles. | Maintain appropriate quality assurance, quality control and production records. |
| EU plastics measure | Regulation (EU) No 10/2011, as amended: Union list, restrictions, migration testing, DoC and supporting documentation for plastic FCMs. | Review composition, authorization status, SML/OML, NIAS risk, use conditions and information passed through the supply chain. |
| French national framework | Decree No. 2007-766: French national measures, requests for adaptation, written declarations and related obligations. | Identify relevant national measures and determine the applicable DoC and supporting-documentation duties. |
| French material-specific orders | National orders for rubber, silicone elastomers, stainless steel, aluminium and aluminium alloys, among other materials. | Review each material and intended use against the applicable composition, purity, migration or testing provisions. |
| DGCCRF material resources | Material-specific food contact suitability resources (Fiches MCDA and related documents). | Use these resources to structure the assessment while distinguishing binding legal provisions from technical criteria and guidance. |
| ANSES scientific assessment | Scientific health risk assessment for new-substance applications under applicable French rubber or silicone elastomer food-contact measures. | For an applicable rubber or silicone elastomer project, plan migration, exposure, toxicology and other safety evidence for a complete and scientifically supportable dossier. |
How to Determine the Correct France FCM Compliance Pathway
Define the material and its intended downstream use.
Identify the intended food-contact application, relevant food types, contact time and temperature, and whether the material will be used once or repeatedly.
Map the composition and application structure.
Identify base polymers, additives, coatings, printing inks, adhesives and other constituents, as well as the material's position in the downstream structure.
Check harmonized EU measures.
Determine whether an EU-specific regulation or directive applies, and review authorized substances, restrictions, migration limits and documentation duties.
Identify French national requirements.
For materials that are not fully harmonized at EU level, or for which France has additional provisions, review the applicable French orders and DGCCRF resources.
Perform a data-gap review.
Assess composition data, supplier documents, existing DoCs, test reports and technical evidence against the intended French use.
Build the verification and documentation plan.
Where necessary, define migration or compositional testing, arrange laboratory work and oversight, and prepare the DoC, supporting documentation or substance status report. For an applicable rubber or silicone elastomer project, the plan may also include a French national new-substance dossier.
Key French Requirements for Rubber and Silicone Elastomers
Rubber Food-Contact Materials
The French Ministerial Order of August 5, 2020 on rubber materials and articles intended to come into contact with food and on pacifiers for infants and young children applies to rubber materials and articles, relevant intermediate materials, and substances used in their manufacture. It includes authorized components, restrictions and specifications, and migration and residual-content verification requirements. Suppliers should assess the exact rubber composition and intended use rather than rely on a generic “food-grade rubber” description.
Silicone Elastomer Food-Contact Materials
The French Ministerial Order of November 25, 1992 on silicone elastomer materials and articles sets requirements for polymer composition and substances that may be added, together with inertness criteria such as free volatile organic matter, overall migration, peroxides and organotin compounds. A generic “food-grade silicone” designation is not sufficient: suppliers should review composition and confirm that the testing approach supports the intended use.
French National New-Substance Applications for Rubber and Silicone Elastomers (DGCCRF/ANSES)
When a company plans to use a new substance that is not authorized under the applicable French national measures for rubber or silicone elastomer food-contact materials, it may need to prepare an application dossier for submission to DGCCRF. DGCCRF then forwards the dossier to the French Agency for Food, Environmental and Occupational Health & Safety (ANSES) for scientific health risk assessment.
ANSES is generally required to issue a reasoned opinion within six months after receiving a complete dossier. The assessment period may be extended, with justification, for up to another six months. This period does not include the applicant's preliminary data preparation, testing, toxicology work or remediation of dossier gaps, and it should not be presented as a fixed authorization timeline. The outcome depends on dossier completeness, scientific evidence and authority assessment.
How REACH24H Can Help
Declaration of Compliance Preparation and Review: Based on the composition, intended use, testing and supply-chain information provided by the client, REACH24H can assist with preparing or reviewing a DoC against the applicable French food-contact requirements.
French National New-Substance Application Support for Rubber and Silicone Elastomers: For eligible new-substance projects involving rubber or silicone elastomer food-contact materials under French national measures, we can support preliminary pathway assessment and data-gap analysis, plan testing and safety data, compile the technical dossier, support submission to the French authorities and assist with responses to supplementary questions.
Testing Strategy, Laboratory Coordination and Oversight: Based on material composition and intended downstream food-contact conditions, we can design the testing strategy, coordinate with suitable laboratories, and review the test plan, execution and results. Testing is conducted by the selected laboratory; REACH24H provides planning, coordination and technical oversight.
Customized Substance Status Report: We can review the authorization status, permitted scope, maximum use level, specific migration limits and other restrictions for substances intended for use in food-contact materials, and issue a tailored regulatory status report.
Customized Regulatory Training: REACH24H can provide tailored training on French food-contact requirements for R&D, technical, quality and regulatory teams, based on the client's material categories and business needs.
Regulatory Translation: We provide French-to-English, French-to-Chinese and other multilingual translation support for relevant French orders, implementing texts, DGCCRF technical resources and project documentation.
Regulatory Consulting: We provide customized advice on applicable regulations, substance authorization, intended-use conditions, supply-chain documentation and France market requirements.
Information Typically Required for a France FCM Assessment
The exact information depends on the material category, intended downstream use and selected service. A new-substance dossier for an applicable rubber or silicone elastomer project will normally require additional migration, exposure, toxicology and safety-assessment evidence.
| Information Category | Typical Information |
|---|---|
| Material and intended use | Material or substance name, grade, function, intended downstream food-contact application and position in the final structure. |
| Composition and supply-chain information | Formula or substance list, CAS numbers, content or use levels, raw-material specifications, supplier DoCs and other compliance statements. |
| Food-contact conditions | Expected food types, contact time and temperature, surface-area-to-volume ratio, and single-use or repeat-use conditions. |
| Testing and safety evidence | Existing migration tests, compositional tests, toxicology data, risk assessments and other supporting documents. |
| Project background | Target markets, customer or platform requirements, planned launch timing, current compliance questions and whether other countries are in scope. |
Why Choose REACH24H?
9
global branches
300+
specialists
15,000+
enterprises served
20+
certified toxicologists
Long-Term Focus on Global Food Contact Regulations
REACH24H continuously tracks food-contact regulations in China, the EU, the United States, Japan and other major markets. This enables the team to assess French requirements from the perspectives of legal applicability, substance status, testing, documentation and supply-chain communication.
Multi-Market Project Experience and Integrated Planning
Our team has experience with EU food-contact new-substance projects, U.S. FDA Food Contact Notifications, DoC projects and global FCM compliance work. For suppliers serving more than one market, we can help map regulatory differences and identify opportunities to reuse appropriate data and testing evidence.
Multidisciplinary Technical Team
The project team brings together expertise in regulatory affairs, chemistry, polymers, toxicology, food science and testing. This supports coordinated work from composition review and migration or exposure analysis to technical dossier preparation.
Laboratory Coordination and Multilingual Support
REACH24H can help screen and coordinate laboratories according to project needs, and can support technical communication, regulatory translation and document preparation in Chinese, English, French and other languages as required.
Frequently Asked Questions
FRANCE FCM COMPLIANCE SUPPORT
Get a France Food Contact Materials Compliance Plan
If your PP, PET or other plastic resin, rubber, silicone elastomer, coating, printing ink, additive or other material is intended for supply into the French food-contact market, submit the material name or grade, composition, intended downstream use, food-contact conditions, existing test reports and customer requirements.
REACH24H can assess the applicable regulatory framework, identify evidence gaps and recommend the appropriate substance review, testing-oversight or documentation support, as well as new-substance support where relevant to rubber or silicone elastomer food-contact materials.
Assessment Focus
✓ Material name or grade and composition
✓ Intended downstream use and food-contact conditions
✓ Existing test reports and customer requirements
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