LFGB vs FDA vs EU 10/2011: Which Applies to You

LFGB vs FDA vs EU 10/2011: Which Applies to You

The comparison

EU 10/2011FDA 21 CFRLFGB (Germany)
Scopeplastic food-contact articlesfood-contact substancesfood-contact articles, national
BasisUnion list + OML/SMLpermitted substances + extraction limitsEU rules + sensory/transfer tests
DeclarationDoC requiredstatement of compliancedeclaration + test report
Sensory testnot centralnot centralyes — odour and taste transfer
Typical lead time2–4 weeks2–4 weeks3–5 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

MarketWhat to prepare
EU (general)DoC + migration report per EU 10/2011
Germanyabove + LFGB sensory test report
USstatement of compliance + extraction test per 21 CFR
UKretained EU law, GB version of the DoC
Middle Eastoften EU-format DoC accepted; check with the importer
Australia/NZAS 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

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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