The EU LFGB certification (Lebensmittel- und Futtermittelgesetzbuch, i.e., the German Food and Feed Code) is Germany's mandatory safety regulation for food contact materials and articles. Although it is a German national law, given Germany's status as a core EU market, its requirements are widely regarded as the "common standard" for entering the EU food contact materials market. For the German market in particular, LFGB compliance is an absolute necessity.

I. Core Positioning and Scope of LFGB

LFGB was enacted in 2005, replacing the former German Food and Commodities Act (LMBG). Its core purpose is to limit the migration of hazardous substances from food contact materials, ensuring that materials do not endanger human health or affect the organoleptic properties of food (e.g., odor, taste) during contact processes such as serving, processing, and transportation.

The scope of applicable products covers virtually all materials and articles that come into direct or indirect contact with food, including but not limited to:

  • Tableware: plastic bowls, glass cups, ceramic plates, stainless steel cutlery
  • Kitchenware: non-stick pan coatings, silicone spatulas, baking molds
  • Food packaging: plastic bags, aluminum foil, paper straws, can interior coatings
  • Kitchen appliance contact parts: metal pipes in coffee machines, baking trays in bread makers
  • Others: bottle cap sealing gaskets, conveyor belts for food processing equipment

II. Core Requirements and Test Items

LFGB's requirements for food contact materials revolve around "safety" and "organoleptic compliance." Test items vary by material type (plastics, metals, ceramics, rubber, etc.) and primarily include the following:

1. Hazardous Substance Migration Limits

Substances that may migrate from materials into food (such as heavy metals, additives, residual solvents, etc.) must not exceed prescribed limits, so as to avoid endangering health.

  • Overall Migration Testing: For materials such as plastics, rubber, and coatings, this test simulates the total quantity of substances migrating into food under different temperature and time conditions. The results must comply with specified limits (e.g., for plastics at 40 degrees Celsius, the migration limit is 10 mg/dm squared).
  • Specific Migration Testing: For known hazardous specific substances (such as heavy metals like lead, cadmium, and mercury; Bisphenol A (BPA) and phthalates in plastics; nitrosamines in rubber), migration levels are restricted (e.g., the migration limit for lead is 0.01 mg/kg).

2. Organoleptic Property Requirements

Materials must not cause off-odors, discoloration, or taste changes in food due to migrating substances.

  • Organoleptic Testing: Professional assessors conduct olfactory, gustatory, and visual evaluations using "food simulants" (such as distilled water, acetic acid, ethanol, etc., which simulate the pH and fat content of different food types) to ensure that migrating substances from the material do not affect the organoleptic properties of food.

3. Prohibited Hazardous Substances

Certain high-risk substances are explicitly prohibited from use in food contact materials, such as:

  • Unapproved plasticizers and stabilizers in plastics
  • Excessive release of nitrosamines (potentially carcinogenic) from rubber products
  • Harmful fluorescent whitening agents in paper products

4. Additional Requirements for Specific Materials

  • Metals and Alloys: For example, stainless steel must be tested for migration of chromium, nickel, manganese, and other metals.
  • Ceramics and Glass: Focus on the release of heavy metals such as lead and cadmium, especially from colored glazes.
  • Wood and Bamboo Products: Limits on residues of preservatives and pesticides.
  • Silicone Products: Testing for volatile substances and residual monomers (such as siloxanes).

III. LFGB Certification Process

LFGB does not involve a "certificate" issued by an official authority. Rather, compliance is demonstrated through testing by German-accredited third-party laboratories that issue test reports confirming conformity with LFGB requirements. The process is as follows:

  1. Determine Product Category and Material: Identify the product material (e.g., plastic, ceramic) and usage scenario (e.g., contact with hot food, acidic food) to select the applicable test standards.
  2. Select an Accredited Laboratory: Testing must be performed by a German-accredited laboratory (such as TUV Rheinland, SGS Germany, Intertek Germany, etc.) with DIN EN ISO/IEC 17025 accreditation.
  3. Sample Testing: Based on material type and usage conditions, conduct overall migration, specific migration, organoleptic testing, and other relevant tests (e.g., plastic tableware requires overall migration testing plus BPA migration testing plus organoleptic evaluation).
  4. Obtain Test Report: Upon passing the tests, the laboratory issues an LFGB compliance report containing product information, test items, results, and conclusions.
  5. Market Access: Products with a compliant test report may enter the German and EU markets. No official registration is required, but the report must be kept on file for inspection (German regulatory authorities may conduct spot checks).

IV. Relationship with Other EU Regulations

At the EU level, there are general food contact material regulations (e.g., Regulation (EC) No. 1935/2004 for all materials, and Regulation (EU) No. 10/2011 specifically for plastics). The relationship between LFGB and EU regulations is as follows:

  • Complementarity: LFGB requirements are typically stricter than EU regulations (e.g., lower limits for certain heavy metals, or additional test items not covered by EU regulations).
  • Regional Specificity: To enter the German market, products must simultaneously comply with EU regulations and LFGB (or at least treat LFGB as the baseline). While other EU member states may accept products compliant with EU regulations, the German market places greater emphasis on LFGB.

V. Important Notes

  1. Mandatory Nature: The German market enforces strict oversight of food contact materials. Non-LFGB-compliant products may be detained at customs, recalled from the market, or even subject to fines.
  2. Re-testing after Material Changes: If the product formulation, manufacturing process, or raw material supplier changes, re-testing is required to ensure continued compliance.
  3. Labeling Practices: LFGB does not mandate a specific marking, but many companies label their products as "LFGB-compliant" or use the commonly recognized "fork and knife symbol" (not legally required, but widely accepted in the market as a compliance signal).
  4. Test Report Validity: There is no fixed validity period, but the report must reflect the current product status. If regulations are updated (e.g., limit values are adjusted), re-testing under the new requirements is necessary.

In summary, LFGB serves as a "safety passport" for food contact materials entering the German and EU markets. Its core mechanism is rigorous migration testing and organoleptic evaluation to ensure that materials have no adverse effects on food safety or sensory properties. Companies must select the appropriate test items based on product type and undergo testing by a German-accredited laboratory in order to successfully enter the target market. GreenArk (Shenzhen) Certification Co., Ltd. provides professional LFGB compliance consulting and testing coordination services to help your products navigate the German market with confidence.