Build a food contact material compliance record
Traceability, declarations of compliance, migration limits and recycled plastic: what the food contact pack checks.
DPP Shield editorial team · Updated:
Food contact materials are not under an ESPR passport mandate, but their compliance data fits a passport well. DPP Shield's food contact pack checks traceability, the written declaration of compliance for plastics, migration limits, the source of recycled plastic and the bisphenol A ban.
What applies today
Regulation (EC) No 1935/2004 sets the framework: materials must be traceable at all stages, labelled “for food contact” or with the glass-and-fork symbol unless their purpose is obvious, and made under good manufacturing practice (Regulation (EC) No 2023/2006). Plastics follow Regulation (EU) No 10/2011: a written declaration of compliance, an overall migration limit of 10 mg/dm² and specific migration limits for listed substances.
Recycled plastic must come from an authorised or listed recycling process (Regulation (EU) 2022/1616), and Regulation (EU) 2024/3190 bans bisphenol A once its transitional periods end. The pack is material-specific: the plastics rules apply to plastic and multilayer materials.
What the pack checks
DPP Shield validates a passport against the bundled EU-FCM pack, which is a draft readiness pack, plus the ESPR core checks every category shares: identifiers, the economic operator, the data carrier, substances of concern and passport availability. Required findings block publication; findings to check are flagged for review. Each finding in the console names its rule and source.
Required - blocks publication
- A traceability reference such as a batch or lot.
- For plastics: the written declaration of compliance.
- Overall migration at or below 10 mg/dm², and the specific migration limits met.
- Recycled plastic only from an authorised or listed process.
- No bisphenol A once the transitional periods end.
What it flags for review
These do not block publication, but resolve each one before the passport goes public.
Check - flagged for review
- Manufacturer identity.
- The “for food contact” wording or the glass-and-fork symbol.
- Good manufacturing practice.
- A dated declaration of compliance.
- Supporting documentation kept for authorities.
Evidence to collect
Attach these in Documents and link them to the passport, or request them from suppliers.
Typical evidence
- The dated declaration of compliance (Annex IV for plastics).
- Migration test reports with the simulants, time and temperature.
- The supporting documentation behind the declaration.
- The recycling process authorisation reference.
- Supplier declarations for substances and additives.
Build the passport step by step
- Create the product with the category Food contact - in Products, by CSV import or from a connected store.
- Open DPPs and choose Create passport: the form shows the food contact fields together with the shared blocks (identifiers, manufacturer, materials, substances of concern, data carrier and passport availability).
- Choose the material type first; the plastics rules depend on it.
- Record the contact conditions - food types, time and temperature - that the tests covered.
- Keep the supporting documentation restricted: it is for business customers and authorities.
- Attach the evidence in Documents and send supplier requests for anything you cannot support yourself.
- Run Validate EU and work through the findings until no required finding is left.
- Preview the public page, redact commercially sensitive fields, then publish.
Before you publish
Because the bundled packs are drafts, publishing needs an accountable override approved by a second owner or administrator until your platform operator activates a legally reviewed pack. The readiness score is not a legal assessment: confirm the obligations that apply to your product with your compliance adviser.
A declaration of compliance only covers the conditions it was tested for; record them so a customer can see whether their use is covered.