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Under framework Regulation (EC) No. 1935/2004, the European Union (EU) states Food Contact Materials (FCM) must display the internationally recognised glass/fork symbol before they can be sold in the EU, unless the articles are clearly intended to come into contact with food due to their characteristics. Similar to the European CE Mark, the glass/fork symbol indicates that food and drink in contact with the product will be safe for human consumption.

Regulation (EC) No. 1935/2004 also requires FCM to be manufactured to GMP. GMP therefore becomes the basic control measure and procedure manufacturers should pursue to produce safe and compliant FCM.

EU regulations that cover FCM include:

  • No. 1935/2004 – lineout of GMP requirements
  • No. 882/2004 – for officials looking at FCM compliance
  • No. 2023/2006 – for manufacturers. Defines scope, definitions, quality assurance (QA)/quality control (QC) systems, documentation
  • No. 282/2008 – amends No. 2023/2006

Stakeholders should note that, while Regulation (EC) No. 1935/2004 requires FCM to be manufactured to GMP, it is Regulation (EC) No. 2023/2006 that defines GMP for FCM. In Article 3 (a) it is defined as:

“‘Good Manufacturing Practice (GMP)’ means those aspects of quality assurance which ensure that materials and articles are consistently produced and controlled to ensure conformity with the rules applicable to them and with the quality standards appropriate to their intended use by not endangering human health or causing an unacceptable change in the composition of the food or causing a deterioration in the organoleptic characteristics thereof.”

To implement GMP, manufacturers must implement a robust system of Quality Assurance (QA) and Quality Control (QC) – the building blocks of GMP – throughout the production chain. QA is a mechanism to help manufacturers control their processes and QC helps them control quality.

The manufacturer is responsible for implementing a documented QA system that ensures:

· Employees are sufficiently trained

· Responsibilities are defined

  • Correct organization and processes are in place
  • Traceability is assured
  • Suitability to manufacturing safe, compliant FCM
  • Technical know-how is in place to control:
    • Chemical processes
    • Processing machine
    • Workplace conditions
    • Treatment of products

Central to achieving GMP is the correct choice of materials and suppliers, since they will have a major impact upon the management of the production process. The QC system must also be effective and suitable for controlling quality. It must run from raw materials and parts selection, through manufacturing, transportation, storage, and include supervision and corrective actions.

A robust QC system will allow:

  • Intervention in the production process
  • Corrective measures to ensure compliant production
  • Illustrate effectiveness to authorities

Given the number of economic operators that can be included in the supply chain, it is vital for the manufacturer to ensure that each operator is individually compliant with their own legislative requirements, and that they are providing quality products to their customers.

The key to showing compliance with GMP, which cannot be tested, to authorities is documentation, which is regularly requested. To implement effective QA and QC systems, the manufacturer must create clear and accurate documentation – either on paper or electronically. The system must contain supportive documents, including details of specifications, details of material composition, Declarations of Conformity and test report, and operative documents. These might include documents detailing:

  • Selection of materials
  • Registration of production data
  • Production controls – e.g. temperature records, cleaning charts
  • Procedure of corrective action
  • Control of finished product – e.g. testing
  • Personal training
  • Storage management
  • Distribution/Shipping protocols

To implement GMP, stakeholders should follow these ten golden rules to GMP compliance:

  1. Get the facility design right from the start
  2. Create good procedures and ensure they are followed
  3. Validate the processes
  4. Identify responsibilities and roles
  5. Keep good records
  6. Train and develop staff
  7. Practice good hygiene
  8. Maintain facility and equipment
  9. Build quality into the lifecycle
  10. Perform regular audits

SGS Food Contact Materials Services

SGS offers a range of services to help companies develop and market FCM. Their global network of accredited laboratories can assist with testing and certifying FCM against local and regional regulations in Europe, North American, South American (Mercorsur) and the Asian Pacific. SGS also offers GMP certification for food packaging materials, based on BSI PAS 223, and GMP audits for management systems, based on FSSC 22000 part one and two.

To learn more about SGS’s Food Contact Materials Services.

For more information, please contact:

Dr. Udo Krischke
Consumer and Retail
Global Technical Manager RSTS & Operational Integrity Manager
Tel: +49 (0)6128 - 744 235



About SGS

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 95,000 employees, SGS operates a network of over 2,400 offices and laboratories around the world.