Food Contact Materials in Kitchen Appliances: EU, US Rules
Updated 2026-11-09
Every part of a kitchen appliance that touches food is a food-contact material. In the EU it needs a declaration under Regulation (EC) 1935/2004, migration testing under Regulation (EU) 10/2011 for plastics, and compliance with the BPA ban in Regulation (EU) 2024/3190. In the US it needs materials acceptable under FDA rules in 21 CFR Parts 170–199.
Food contact is a separate legal system
Electrical safety certification gets the attention, but food contact stops more private-label launches than any failed dielectric test. The reason is simple: safety certification looks at one appliance, while food contact looks at every material that touches food, at the temperature and duration of real use, and it is checked by the buyer’s quality team rather than by a lab alone.
For this product range, food-contact surfaces include:
| Category | Food-contact parts |
|---|---|
| Air fryer | Basket, rack, drip tray, silicone liners |
| Stand mixer | Bowl, whisk, dough hook, splash guard |
| Egg cooker | Egg tray, poaching cups, lid, water tray |
| Contact grill | Grill plates, drip tray, spatula |
| Toaster | Slot guards, bun warmer rack, sandwich cage |
| Milk frother | Jug, whisk, lid, seal |
| Electric lunch box | Inner container, lid, seal, dividers, cutlery |
| Portable blender | Jar, lid, seal, blade gasket |
| Cup warmer | Only if a mug or spoon is included |
| Hand warmer | None |
The EU framework in four layers
Layer 1: Regulation (EC) 1935/2004. The framework regulation. Materials must not transfer constituents in quantities that endanger health, change food composition unacceptably, or deteriorate taste and smell. Manufacturers must provide a declaration of compliance, hold supporting data, and maintain traceability.
Layer 2: Regulation (EU) 10/2011 for plastics. The most detailed measure for this industry, because most appliance parts are plastic. It sets an overall migration limit of 10 mg/dm², individual specific migration limits, rules for substances not on the positive list, and a declaration of compliance requirement at every stage of the chain.
Layer 3: Regulation (EU) 2024/3190 for bisphenols. Applies from 20 January 2025 and bans bisphenol A in plastics, coatings, adhesives, rubbers, silicones, printing inks and ion-exchange resins used in food contact. Transition rules apply: repeat-use articles such as kitchenware fall under the main deadline of 20 July 2026, and some single-use and professional equipment cases run later. A supplier who still uses a PC part made with BPA needs a replacement plan, not a certificate.
Layer 4: national rules such as the German LFGB. German retailers and discounters commonly ask for LFGB testing and BfR recommendation conformity as an extra assurance. It sits on top of EU compliance.
The US system works differently
The US has no single food-contact regulation. Instead, materials must be acceptable under the Federal Food, Drug and Cosmetic Act, either because they are listed in FDA regulations in 21 CFR Parts 170–199, because they are the subject of an effective food-contact notification, or because they are generally recognised as safe for the use.
For this industry the relevant parts are usually:
| Part | Covers |
|---|---|
| 21 CFR 175.300 | Resinous and polymeric coatings, including non-stick coatings |
| 21 CFR 177.1520 | Olefin polymers such as PP and PE |
| 21 CFR 177.1580 | Polycarbonate resins |
| 21 CFR 178 | Adjuvants, production aids and sanitisers |
A US buyer will normally accept a supplier declaration that names the regulation section for each material, backed by migration data where the use is fatty or hot. Vague “FDA approved” letters are rejected by serious quality teams, because FDA does not approve materials; it authorises uses.
What the laboratory actually does
| Test | Purpose | Typical trigger |
|---|---|---|
| Overall migration | Total transfer into simulant, limit 10 mg/dm² | Every plastic part |
| Specific migration | One substance against its own limit | Monomers, additives, plasticisers |
| NIAS screening | Unknown substances from degradation | Coatings, recycled material |
| Sensorial test | Taste and odour transfer | Jugs, lids, containers |
| Repeated-use test | Migration after washing cycles | Dishwasher-safe claims |
| Metal release | Heavy metals from steel and aluminium | Bowls, blades, trays |
| Temperature-conditioned test | Migration at use temperature | Air fryer baskets, grill plates |
The choice of simulant matters. Acidic foods such as tomato use acetic acid; fatty foods use vegetable oil or a substitute; milk uses a different set. A report tested only with water at 40 °C does not cover a basket that reaches 200 °C with fatty food.
PFAS and coatings: how to answer the question
PFAS is the most common question from buyers in 2026, and the most common place where suppliers overclaim; the California Prop 65 chemical rules are the second most common.
Current position, in plain terms:
- There is no EU-wide ban on all PFAS in food-contact materials. The universal PFAS restriction proposal is in the REACH process, and its scope and timing are still being decided.
- Some member states and some US states have already restricted specific PFAS uses, particularly in food packaging.
- PTFE coatings remain lawful when they comply with food-contact rules, but the commercial pressure is real.
- “PFAS free” is a material statement. It needs a declaration from the coating supplier naming the chemistry, not a marketing sentence.
The practical answer for an importer is a document pack: a coating declaration naming the substance family, a migration report for the coating, and a written statement of which regulations the coating meets.
Documents a buyer should receive for every food-contact part
| Document | Content |
|---|---|
| Declaration of compliance | Regulation (EC) 1935/2004, plus 10/2011 for plastics |
| Migration test report | Simulants, temperatures, results, limits |
| Material specification | Resin grade, supplier, colour masterbatch |
| Coating declaration | Primer and topcoat chemistry, compliance statement |
| BPA statement | Compliance with Regulation (EU) 2024/3190; packaging marks on the carton |
| FDA statement | 21 CFR section per material |
| LFGB report | Where a German buyer requires it |
| Traceability sheet | Batch and material records |
Why food-contact files get rejected
- A declaration with no test data behind it. The declaration is a legal statement, and the buyer can ask for the data.
- Wrong simulant or temperature. A 40 °C water test offered for a 200 °C basket.
- Material named in the declaration does not match the specification. A common finding when a factory changes resin supplier without telling the brand.
- Colour masterbatch not covered. The declaration covers natural resin, but the product is black.
- BPA issue in a PC part. The part is legal under old stock rules but not for new production.
- Coating declared only for the topcoat, while the primer is a different chemistry.
- No repeated-use data for a dishwasher-safe claim.
- Traceability missing when a buyer audits the supply chain.
Market summary
| Market | Framework | Key point for appliances |
|---|---|---|
| EU | 1935/2004, 10/2011, 2024/3190 | Declaration plus migration data; BPA ban applies |
| Great Britain | Retained EU food-contact law | Same documents, UK-based responsible operator |
| United States | FD&C Act, 21 CFR 170–199, FCNs | Cite the regulation section per material |
| Canada | Food and Drugs Act, Health Canada letters of no objection | Supplier letters plus migration data |
| Australia / NZ | Food Standards Code, industry arrangements | Buyer-specific evidence requests |
| Gulf | GSO standards referencing EU methods | EU-style reports usually accepted |
| Japan | Food Sanitation Act, positive list for utensils | Positive-list compliance for plastics |
Frequently asked questions
Who issues the declaration of compliance? The business placing the material or article on the market, which in practice means the material supplier and the appliance manufacturer each issue one for their stage. A brand owner should hold the full chain.
Is a “food grade” certificate acceptable? Rarely. It is not a legal category in the EU or the US. Buyers want a declaration naming the regulation plus migration data.
Do metal parts need migration testing? They need a material declaration, and often a heavy-metal release test, especially for aluminium with a coating and for stainless steel in contact with acidic food.
Does a non-stick coating need its own declaration? Yes. Coatings are multi-layer systems, and the declaration must cover the primer and the topcoat.
What changes if the product is sold as dishwasher-safe? Repeated-use testing is needed, because washing cycles can degrade the surface and increase migration.
Can one migration report cover several colours? Only if the pigment system is the same and the lab has assessed the worst case. A different colour masterbatch is a different formulation.
How does this relate to the safety certification files? They are separate files. A CE technical file does not automatically contain food-contact evidence, and a food-contact report does not satisfy the LVD or UL requirements. Both belong in the product file the importer keeps.
For market context see the EU/, the US/, the UK/ and Japan and Korea/. Ask us for model-specific data on materials and test reports through our contact page/.
Frequently asked questions
Which appliance parts count as food contact?
Anything the food or drink touches: air fryer baskets and racks, blender jars and blade gaskets, mixer bowls and dough hooks, egg trays and lids, grill plates, lunch box containers, milk frother jugs and whisks, and any spoon or cup included in the box. The outside of a mug warmer is not food contact; a mug sold with it is.
What does Regulation (EC) 1935/2004 require?
It is the EU framework. Materials must not transfer constituents in quantities that endanger health, change the composition of food unacceptably, or deteriorate its taste and smell. Manufacturers must provide a declaration of compliance, keep supporting test data, and be able to trace materials. Specific measures, such as Regulation (EU) 10/2011 for plastics, set the detailed limits.
What does Regulation (EU) 10/2011 require for plastic parts?
It sets an overall migration limit of 10 mg per dm² of surface, individual specific migration limits for listed substances, and rules on substances not listed. It also requires a written declaration of compliance at each stage of the supply chain, naming the materials, the migration testing done and the conditions of use.
Is BPA still allowed in food-contact plastics?
Not in the EU for the materials covered by Regulation (EU) 2024/3190, which applies from 20 January 2025 and bans bisphenol A in plastics, coatings, adhesives, rubbers, silicones, printing inks and ion-exchange resins. Transition periods apply, with repeat-use articles such as kitchenware covered by the main deadline of 20 July 2026. US rules are different and are set through FDA food-contact notifications and authorisations.
What is the difference between overall and specific migration?
Overall migration measures the total mass of substances that move from the material into the food simulant, and it is a proxy for inertness. Specific migration measures one named substance against its own limit. A part can pass overall migration and still fail a specific migration limit for a monomer, additive or processing aid.
Does LFGB matter if I already comply with EU law?
For German retail, yes. The German Food and Feed Code, supported by BfR recommendations, is often requested by retailers and discounters as an extra assurance, and a LFGB test report is a common private-label requirement. It sits on top of EU compliance rather than replacing it.
What is the position on PFAS in food-contact coatings?
There is no EU-wide ban on all PFAS in food-contact materials at the time of writing. The universal PFAS restriction proposal is progressing through the REACH process, and some member states and some US states have already restricted specific uses. A supplier should answer with a material declaration for the exact coating, not a general claim.
How long does a food-contact test programme take?
Timelines are quoted by the laboratory and depend on the number of parts, simulants, temperatures and repeat-use cycles. A single plastic part with one simulant is a small job; a full appliance with five materials, three simulants and repeated-use conditions is a project.
Sources
- Food contact materials framework Regulation (EC) 1935/2004
- Plastics food contact Regulation (EU) 10/2011
- BPA ban Regulation (EU) 2024/3190 (consolidated text)
- European Commission note on the BPA prohibition from 20 January 2025
- FDA 21 CFR Part 177 (indirect food additives: polymers)
- FDA 21 CFR Part 178 (adjuvants, production aids, sanitisers)
- German Federal Institute for Risk Assessment (BfR)
- ECHA PFAS hotspot
- General Product Safety Regulation (EU) 2023/988
- RoHS Directive 2011/65/EU
- UKCA marking guidance (retained food-contact law context)