Declaration of Conformity for Food Contact Materials: UK HACCP Documentation

The Legal Obligation Under UK Retained Law

The obligation to provide a written Declaration of Conformity (DoC) for food contact materials is retained from Article 16 of Regulation (EC) No 1935/2004 and Article 15 of Regulation (EU) No 10/2011 as assimilated EU law in Great Britain. The FSA confirms that these obligations remain fully in force post-Brexit and are enforceable by Local Authority EHOs and Trading Standards Officers. Food businesses purchasing professional scoops must request and retain the DoC from their supplier.

Mandatory Content Under UK Law

The DoC must include: identity and address of the operator issuing the declaration; object identity (product name, code, material description); date of the declaration; explicit confirmation of compliance with retained Reg. EC 1935/2004 and retained Reg. EU 10/2011; information on restricted constituents and migration values; specific use conditions (maximum temperature, food type, contact frequency); reference to applicable legislation. The FSA's food contact materials guidance (available at food.gov.uk) sets out what constitutes adequate documentation for UK enforcement purposes.

📚 BIBLIOGRAPHY AND SOURCES

1. Retained Regulation (EC) No 1935/2004, art. 16 — Declaration of conformity (GB). https://www.legislation.gov.uk/eur/2004/1935

2. Retained Regulation (EU) No 10/2011, art. 15 and Annex IV. https://www.legislation.gov.uk/eur/2011/10

3. FSA — Food contact materials guidance for UK food businesses. https://www.food.gov.uk/business-guidance/food-contact-materials

4. Trading Standards — Enforcement of food contact material regulations. https://www.tradingstandards.uk

5. EFSA — Technical guidance on declarations of conformity for food contact materials. https://efsa.onlinelibrary.wiley.com