Compliance
REACH and food contact: what the paperwork actually proves
REACH is about chemicals in an article. Food contact is about what migrates out of it. They are different tests with different owners, and a single certificate rarely covers both.
At a glance
Specification at a glance
| Question | Answer | Document | Owner |
|---|---|---|---|
| Does it contain SVHC above 0.1 percent? | Supplier declaration against the current candidate list | Declaration, or test report per article | Material supplier |
| Is it food contact safe? | Depends on use conditions and migration | Declaration of compliance, migration test | Converter or brand owner |
| Are PFAS present? | Increasingly restricted, ask explicitly | Declaration or targeted test | Material supplier |
| Is heavy metal content controlled? | Tested per market requirement | Test report | Laboratory |
REACH in one paragraph
REACH requires that articles placed on the EU market do not contain substances of very high concern above a threshold, and that buyers are informed when they do. For nonwoven, the practical document is a declaration against the current candidate list, refreshed when the list changes.
A declaration is a statement by the supplier, not a certificate. Its value depends on whether the supplier knows the formulation of every input, which is why the question should go to the fibre and finish suppliers as well as the fabric producer.
Food contact is about migration, not purity
A material can be chemically clean and still fail food contact because something migrates into the food under the conditions of use, for example hot, fatty or acidic contact. Compliance is demonstrated by migration testing for the intended use, and the declaration of compliance names the article and the conditions it covers.
If the intended use is dry contact at ambient temperature and the declaration covers hot fatty contact, you have a broader document than you need. If it is the reverse, you have nothing.
The questions to send with an enquiry
Name the market, the food type, the contact conditions and the test your customer accepts. Ask for the declaration of compliance with its scope, and for the SVHC declaration date. A supplier who cannot name the scope usually cannot support the claim.
What a declaration of compliance should contain
The article it covers, the substances of concern and their migration limits, the conditions of use (food type, temperature, contact time), the test basis, and the date. A document without the conditions of use is a document that cannot be checked against your product.
Ask for the version that matches your use. A declaration for dry ambient contact does not cover hot fatty food, and using it as if it did is a compliance failure with paperwork attached.
Tell us the application and the acceptance test
The reply names a grade we can run, the tolerance we can hold and a lead time, or says plainly that we cannot make it.
Questions
Common questions
Do you provide REACH declarations?
Yes, per order, stating the date of the candidate list used. Where a substance is present above the threshold, it is disclosed rather than glossed over.
Can you certify food contact for our product?
We can supply material data and declarations for the fabric. The declaration for the finished article belongs to whoever converts and packs it, because the converting materials become part of the contact surface.
How often does the SVHC list change?
The candidate list is updated periodically, typically twice a year. A declaration older than the last update should be refreshed before it is relied on.