Clad metal for European cookware makers
European buyers need a declaration of compliance they can file, not a promise. The material is the easy part; the document set is what decides whether the order starts.
At a glance
Specification at a glance
| Item | What EU buyers usually ask | How it is handled |
|---|---|---|
| Framework | Compliance with Regulation (EC) No 1935/2004 and GMP Regulation (EC) No 2023/2006 | Stated in the declaration of compliance |
| Declaration | A written declaration of compliance for the material supplied | Issued per structure and per grade combination |
| National rules | German LFGB, Italian ministerial decree, French DGCCRF | Declared where the grades and the finish are covered |
| Migration | Test data for the intended use, or a basis for your own testing | Discussed per project; not claimed where no report exists |
| REACH | SVHC statement above 0.1 percent | Issued with the documents |
| Traceability | Batch reference to mill certificate | Batch reference on every label |
What the framework actually requires
Food-contact materials in the EU sit under Regulation (EC) No 1935/2004, with good manufacturing practice under Regulation (EC) No 2023/2006. For metals there is no single harmonised measure at EU level, so member states apply national rules; Germany works through the LFGB and its BfR recommendations, Italy through its ministerial decree of 1973, France through DGCCRF guidance, and the Council of Europe resolution on metals and alloys is used as a common technical reference.
In practice this means the buyer needs a declaration of compliance that names the material, the grades, the intended use and the conditions the declaration covers. Anything broader than that is not a declaration, it is marketing.
What our declaration covers, and what it does not
We can declare the grades supplied, the layer structure, the surface finish, the intended food-contact use, and compliance with the GMP regulation in our process. We can state that no SVHC above 0.1 percent is intentionally present in the material as supplied. What we do not do is issue migration test results we have not run: if your file needs nickel or heavy-metal migration data for the finished pan at its use conditions, that testing is arranged and the report goes into the file with the actual conditions stated.
National routes, one material
A German buyer asks for LFGB, an Italian buyer asks for the ministerial decree, a French buyer asks for DGCCRF. The material can satisfy all three at once if the grades are the ones those rules recognise, which is why the grade combination is agreed before the order and not after. If a buyer needs a specific national statement, say so in the enquiry and it is written into the declaration rather than promised afterwards.
Importer obligations that are not the supplier's
The importer of record carries obligations that no Chinese supplier can discharge for them: the entry declaration, the duty, and packaging and producer-responsibility registrations in some member states. We supply the documents behind the material; the registration and the entry belong to your company or your representative. It is worth separating the two lists before the first shipment, because a missing registration is discovered at the border, not at the factory.
Why the batch record matters in Europe
When a retail chain audits a cookware brand, the question is usually not whether the steel is 304 but whether the pan in the shop can be traced to a mill certificate and a declaration. That trace runs through the batch reference on the label, the inspection record and the declaration covering the structure. Building it costs a label field; rebuilding it after an audit is expensive.
Questions
Common questions
Do you issue a declaration of compliance?
Yes, for the structure and grade combination supplied, naming the material, the grades, the intended use and the conditions covered. It is not a blanket certificate, and it does not claim migration testing that has not been done.
Is clad metal covered by an EU harmonised measure?
There is no single harmonised EU measure for metals and alloys in food contact. Regulation 1935/2004 and the GMP regulation apply, and member states apply national rules such as LFGB, the Italian ministerial decree and DGCCRF guidance.
Can you provide migration test reports?
Where a report exists for the grade and finish supplied it goes with the documents. Where it does not, testing can be arranged against the conditions your file requires, and the report states those conditions.
What about REACH SVHC?
We state that no SVHC above 0.1 percent is intentionally present in the material as supplied. If your file needs a substance-by-substance statement for a specific grade, ask for it in the enquiry.
Do you handle EU import declarations?
No. The importer of record handles the entry, the duty and any packaging or producer-responsibility registrations. We supply the material documents those filings depend on.
Which ports do EU buyers use?
Hamburg, Rotterdam and Koper are the usual entries for this trade. The port is stated in the quotation together with the Incoterm.