LFGB vs FDA vs EU 10/2011: Which Applies to You
The comparison
| EU 10/2011 | FDA 21 CFR | LFGB (Germany) | |
|---|---|---|---|
| Scope | plastic food-contact articles | food-contact substances | food-contact articles, national |
| Basis | Union list + OML/SML | permitted substances + extraction limits | EU rules + sensory/transfer tests |
| Declaration | DoC required | statement of compliance | declaration + test report |
| Sensory test | not central | not central | yes — odour and taste transfer |
| Typical lead time | 2–4 weeks | 2–4 weeks | 3–5 weeks |
Why German buyers ask for LFGB when EU law already covers them
LFGB predates and sits alongside EU harmonisation. Its practical value to a German buyer is the sensory test (§64 LFGB): trained panel assessment of odour and taste transfer. EU 10/2011 does not require this. A German retailer's own QA standard often does.
So: EU compliance is the legal baseline; LFGB testing is a commercial requirement in Germany. Both are usually asked for.
Choosing by destination
| Market | What to prepare |
|---|---|
| EU (general) | DoC + migration report per EU 10/2011 |
| Germany | above + LFGB sensory test report |
| US | statement of compliance + extraction test per 21 CFR |
| UK | retained EU law, GB version of the DoC |
| Middle East | often EU-format DoC accepted; check with the importer |
| Australia/NZ | AS 2070 series, plus importer declaration |
FAQ
Is one test enough for all markets? Rarely. EU and US limits differ, and LFGB adds a test the others do not run.
Can I use the factory's report for my brand? The data may be reused only if the article is identical and the report identifies it. A DoC in your name is a separate document.
How much does testing cost? Typically USD 300–1,200 per SKU per market for standard migration testing.
Next step
Tell us the destination countries. We will list exactly which documents each market needs and what can share one test.
Related reading
- Private Label Program for Distributors
- PP Containers for Hospital and Institutional Catering
- Germany VerpackG and France Triman: EPR Registration for Food Packaging
Models covered on this site: 750 ml PF-RG750 · 1000 ml PF-RW1000 · 950 ml PF-GG950 · see all models in this category.
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