Declaration of Compliance for Food Contact, Field by Field

E1 · EU regulatory gates

The Declaration of Compliance, Field by Field

9 min readFoliware India LLPReviewed 14 September 2026

The short answer

A declaration of compliance is the written statement from a supplier that a food contact article meets the rules applicable to it, with supporting documentation held behind it. For plant fibre tableware there is no EU specific measure and therefore no prescribed EU template, so the fields come from national law and buyer practice. The Netherlands requires a written declaration for wood; Germany works through the BfR Recommendations.

Where the obligation comes from, and where it does not

Regulation (EC) No 1935/2004 is the framework regulation for materials and articles intended to come into contact with food. Article 3 sets the general requirement: materials and articles shall not transfer their constituents to food in quantities which could endanger human health, bring about an unacceptable change in the composition of the food, or bring about a deterioration in its organoleptic characteristics.

Article 16 is the declaration article, and its wording is narrower than most buyers assume. It provides that “the specific measures referred to in Article 5 shall require that materials and articles covered by those measures be accompanied by a written declaration stating that they comply with the rules applicable to them. Appropriate documentation shall be available to demonstrate such compliance.”

The declaration duty is created by specific measures, for the materials those measures cover. The European Commission lists the materials with EU specific measures: plastics under Commission Regulation (EU) No 10/2011, recycled plastics under Regulation (EU) 2022/1616, active and intelligent materials under Regulation (EC) No 450/2009, ceramics under Directive 84/500/EEC, and regenerated cellulose film under Directive 2007/42/EC. Wood, plant fibre, paper and board are not on that list.

That is not a gap you can exploit, because Article 6 fills it: “In the absence of specific measures referred to in Article 5, this Regulation shall not prevent Member States from maintaining or adopting national provisions provided they comply with the rules of the Treaty.” The Commission confirms that national legislation is in place in the majority of Member States and that the rules differ from one to another.

For plant fibre tableware, then, the declaration of compliance is a national law document in some markets, a contractual document in all of them, and an EU-templated document in none. Anyone who sends you a “standard EU DoC” for a leaf plate has adapted a plastics template.

The two national regimes that actually shape the document

Market	What applies to a plant fibre or wood article	Practical consequence for the declaration
Netherlands	The Warenwetregeling verpakkingen en gebruiksartikelen designates materials including hout en kurk, wood and cork, alongside paper and board, and requires a written declaration to be available at all stages of the trade chain except retail	A written declaration is a legal requirement, not a courtesy. Ask for it before the first shipment
Germany	The BfR Recommendations on food contact materials are not binding legal standards, but the Bundesinstitut für Risikobewertung states that they represent the current state of science and technology for fulfilling Article 3(1)(a) of Regulation (EC) No 1935/2004	Reference the relevant BfR Recommendation where one covers the material, and show the reasoning in the supporting file

For Ireland, Sweden, Denmark, France and Norway, confirm the current national provisions with the competent authority before relying on a declaration drafted for another market. Norway sits outside the EU and applies these rules through the European Economic Area framework. Buyers importing into the Netherlands or Germany should treat the two rows above as the baseline and take their own legal advice beyond it.

The document, field by field

Twelve fields. Each one exists because something goes wrong without it.

#	Field	What it must contain	What goes wrong without it
1	Issuing business	Full legal entity name, registered address, country	A trading name nobody can trace to a supplier of record
2	Recipient	The buyer’s legal entity	A declaration addressed to nobody, which nobody can rely on
3	Article identity	Product name, SKU or article code, size, and where relevant the shape	A declaration naming “areca leaf tableware” that no purchase order line matches
4	Material description	Botanical source, part of the plant, any additives or process aids, with explicit negatives	Silence on coatings, which a careful auditor reads as an admission
5	Compliance statement	Regulation (EC) No 1935/2004 and the named national provisions in the destination market	EU law cited alone in a market where national law governs the material
6	Good manufacturing practice	Reference to Regulation (EC) No 2023/2006	No stated link between the article and a controlled process
7	Conditions of use	Food types, maximum contact temperature and time, and whether repeated use is intended	A declaration nobody can check against how the plate is actually used
8	Restricted substances	Any substance subject to restriction, or an explicit statement that none apply	An unanswered question at audit
9	Supporting documentation	The reports held, with references and dates, available on request	Nothing behind the declaration, which Article 16 requires there to be
10	Traceability link	Batch code, lot or production period, and how it maps to the delivered goods	No way to tie the tested material to the pallet
11	Date	Date of issue, and of any revision	A declaration of unknown vintage covering a process that has since changed
12	Signature	Name, position and signature of a person with authority in the issuing entity	A document nobody has taken responsibility for

Field 6 carries more weight than its length suggests. Regulation (EC) No 2023/2006 of 22 December 2006 on good manufacturing practice for food contact materials applies to all sectors and all stages of manufacture, processing and distribution, excluding the production of starting substances, and requires a documented quality assurance system, a quality control system and documented specifications and processing records. It applies to a leaf tableware factory whether or not a specific measure exists for the material.

Field 7 is the one buyers accept as boilerplate and then regret. “Suitable for food contact” without a temperature and a time cannot be checked against a hot buffet or a chilled salad. What conditions to specify, and how to have a laboratory test them, is set out in the guide to migration testing for plant fibre tableware.

The five reasons a European buyer rejects a declaration

These are the rejections that actually happen at onboarding, in order of frequency.

It names a material, not an article. Field 3 is missing or generic, so the buyer cannot map the document to a purchase order line. This is the most common failure and the easiest to fix.

It has no conditions of use. Field 7 is absent or reads “for food contact”. A buyer serving hot food cannot rely on it and their auditor will say so.

There is no traceability link. Field 10 is missing, so nothing connects the declaration to the goods delivered. Article 17 of Regulation (EC) No 1935/2004 requires traceability at all stages to facilitate control, recall and the attribution of responsibility. A declaration that floats free of batch identity does not support that.

It cites the wrong law. Field 5 references only Regulation (EC) No 1935/2004 for a shipment into the Netherlands, where the national Warenwetregeling requires a written declaration for wood and cork among other materials.

The supporting documentation does not exist. Field 9 lists reports, the buyer asks for one, and it cannot be produced. Article 16 requires appropriate documentation to be available to demonstrate compliance. A written claim the supplier cannot support is worse than no declaration.

A sixth, quieter failure: the declaration is correct and nobody updates it when the process changes. Agree a revision trigger tied to a change in raw material source, process or input supplier rather than to a calendar date. How this shows up on a first shipment is covered in the guide to what goes wrong on a first container.

How long to keep it, and who keeps it

Retention periods for food contact documentation are set nationally and by your own quality system rather than by a single EU rule for non-harmonised materials. Fix the period in your supply agreement, hold the declaration for at least the product’s usable life plus your own audit cycle, and confirm the statutory minimum with the competent authority in each destination market.

Hold it yourself rather than relying on a supplier copy or a portal you do not control. If the supplier relationship ends, the declaration covering goods you have already sold is still your evidence. The full onboarding set is listed in the guide to the EU-specific documents a European buyer adds to a standard vendor pack.

Frequently asked questions

Is a declaration of compliance legally required for areca leaf plates in the EU? Article 16 of Regulation (EC) No 1935/2004 creates the duty for materials covered by an EU specific measure, and there is no specific measure for plant fibre or wood. National provisions fill the gap under Article 6, and the Netherlands requires a written declaration for materials including wood and cork. Confirm the position for your own destination with the competent authority.

Can I use a plastics declaration template for a leaf plate? You can borrow the structure, but do not leave in references to Commission Regulation (EU) No 10/2011 as if it applied. It is a specific measure for plastics, and citing it for a plant fibre article tells an auditor the document was not written for the product.

Who signs the declaration, the factory or the exporter? The business placing the article into the supply chain at that stage, signed by a named person with authority in that entity. If you buy through a trading company, take the declaration from the entity you contract with and insist on tracing it back to the manufacturer.

Does the declaration need a batch number? It needs a traceability link that ties it to the goods, which in practice means a batch code, a lot or a production period. Article 17 of Regulation (EC) No 1935/2004 requires traceability at all stages to facilitate control, recall and the attribution of responsibility.

Does a declaration of compliance cover PPWR as well? No. Regulation (EU) 2025/40 requires its own EU declaration of conformity under Article 39, with technical documentation under Annex VII. That is a separate document under a separate instrument, and the evidence behind it is set out in the guide to PFAS limits and substances of concern under PPWR.

References

Regulation (EC) No 1935/2004 of the European Parliament and of the Council of 27 October 2004 on materials and articles intended to come into contact with food. Official Journal of the European Union.
Commission Regulation (EC) No 2023/2006 of 22 December 2006 on good manufacturing practice for materials and articles intended to come into contact with food. Official Journal of the European Union.
Food contact materials: EU legislation and national rules. European Commission, Directorate-General for Health and Food Safety.
Commission Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food. Official Journal of the European Union.
Warenwetregeling verpakkingen en gebruiksartikelen (BWBR0034991). Overheid.nl, Netherlands.
BfR Recommendations on Food Contact Materials. Bundesinstitut für Risikobewertung, Germany.
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste. Official Journal of the European Union, 22 January 2025.

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Next step

Send an enquiry naming the product, the volume and the destination, for example 15 pallets of the Reinforced Round Traditional Patravali Meal Plate, 12 inch round, delivered Hamburg, and list the SKUs the declaration must cover with the food types and contact temperatures your customers use. Foliware India LLP will issue the declaration against that SKU list with the conditions of use stated.

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