Glass Bottle Food Contact Declaration: FDA, EU and LFGB

A food contact declaration for a glass bottle is a signed statement from whoever placed the article on the market that, in its intended use, it will not pass constituents into food at levels that endanger health, alter the food unacceptably or spoil its taste and smell. No single "certificate" exists. What clears a retailer's onboarding or a border query is a pack of four things: material data, a migration or release test report, the declaration itself, and a traceability record. The rules behind that pack differ by market: FDA 21 CFR in the United States, Regulation (EC) No 1935/2004 in the European Union, LFGB and BfR recommendations in Germany, GB 4806.5 in China. On most packs the closure, liner and ink need more paperwork than the glass.

What the declaration states and where it stops

What Europe calls a declaration of compliance is a claim about behaviour under stated conditions. A named legal person makes it for a named article in a named market at a given moment. No government body issues it, no laboratory produces it, it is not a licence, and no expiry date is printed on it. Take it outside those four limits (material, article, market, time) and it has no value. Forwarding an old declaration into a new market creates a compliance problem instead of closing one.

Four consequences matter in practice:

• Scope lives in the conditions. If the sheet omits the food type, the maximum temperature and the contact time, an auditor cannot tell whether your use is inside or outside it, so the document is unusable. The same glass body can be acceptable for ambient water and unproven for a hot-filled acidic sauce or a seventy per cent alcohol tincture.
• Each material has its own declaration. Glass from one supplier, a closure from a second and ink from a third means three declarations that never merge. A single sheet for the glass leaves two thirds of that pack undocumented.
• Rules move. The EU plastics measure has been amended many times and its substance lists extended. A declaration written against a replaced amendment is a historical record, not a live one.
• A claim is not proof. An experienced quality manager will ask next for the tests and material data that stand behind the signature.

This is why asking for "the food contact certificate" backfires. A supplier may send whichever sheet looks most official, which is often the weakest in the set. Ask for the pack by its parts and the answer becomes checkable.

One limit on this article too: it explains which documents are needed, who issues them and how that shifts by destination. It does not say that any plant holds any approval in any market. That can only be shown by documents written for your article.

Which parts of the pack carry the compliance burden

Buyers tend to spend the whole compliance conversation on the bottle and treat the cap as an accessory. That is backwards, and it explains most rejected onboarding submissions. The glass body is normally the simplest component to document.

The glass body

Glass is inorganic and fired. Under normal conditions of food contact it is chemically inert, and it holds none of the monomers, plasticisers, stabilisers or antioxidants that put plastics under a long permitted-substance list. So there is no additive question to answer for the body.

There is a release question. Lead, cadmium and, in some formulations, other heavy metals can enter through raw materials, colouring oxides or decoration, and they can migrate into the contents. Release limits for glass hollowware exist for that reason, and the ISO 7086 series was written for it, keeping the test procedure separate from the permissible limits. Coloured and heavily decorated glass therefore deserves closer attention than flint (clear) glass. An amber bottle coloured by a controlled oxide addition is a different compliance object from a clear bottle with a fired organic decoration on its shoulder.

Closures, liners and gaskets

Requirements multiply at the closure. The metal shell, the plastic liner inside it and the silicone gasket are three separate materials. A dropper, pump or sprayer adds more through the dip tube and the internal spring. Each one touches the contents directly, each is regulated as a food contact material in its own right, and each needs its own conformity position.

• Plastic liners and layers fall under the plastics measure in the EU and the food contact substance provisions in the United States. Their declaration has to identify the article and carry migration data.
• Silicone gaskets are outside the plastics measure altogether, which surprises many buyers. They rest on national assessments and the European resolution on silicone.
• Pulp, parchment or coated board liners sit under the paper and board provisions.
• Cork and other natural materials raise their own questions, including the agents used to treat them.

If your concern is how the closure performs mechanically, not how it is documented, that is covered in our guide to cap application and removal torque testing.

Inks and coatings

Ink sits on the outside of the bottle, so buyers assume nobody regulates it. Then a retailer asks about set-off: ink components moving from the printed face of one article to the food contact surface of another when packs are stacked or nested. The same retailer may ask about the drying and curing regime and residual solvents.

The usual answer cites the framework regulation together with a national or industry standard. The Swiss ordinance on printing inks has become the benchmark many European and global retailers write into supplier requirements, including in markets with no equivalent rule. A supplier able to hand over an ink statement, a set-off or migration test where the pack geometry makes one relevant, and a declaration for the coating system is far better placed than one who can only talk about glass.

Rules and documents by destination market

The table sets each destination against its governing rules, splits the demands on the glass from those on the closure and decoration, and lists the documents and the usual reasons for rejection. Use it for planning. Regulations are named in plain text because they are amended, and you need to confirm the edition in force when the goods ship.

The market is where the goods are sold, not where they are made. Bottles made in China and shipped to a German importer answer to German and European rules on arrival. China's own national standard does not replace that duty. It is a second obligation that governs domestic sale of the same article.

What an acceptable compliance pack contains

The pack is a small bundle built in a fixed order. Material data is the base, because it says what is in the article. Migration testing sits on top of it and shows how the material behaves in the intended use. The declaration summarises both. Traceability ties the tested article to the one on the pallet. A summary sent with no evidence beneath it usually fails review.

The declaration

You can check a declaration in about a minute. It should show:

• the issuing legal entity, with an address where it can really be reached;
• the article, preferably by the plant's own article or mould reference, described closely enough to tell it from a similar bottle in the same range;
• the intended use: food type, maximum contact temperature and contact time;
• the rules it conforms to, by name, not a loose claim of "food grade";
• the basis for the conclusion, whether migration testing, a composition assessment against a permitted list, or an exemption;
• an issue date or revision number, and a named signatory;
• any restriction on use.

The last item is the one a quality manager needs most. It is also the one suppliers most often delete, because they want a sheet that seems to cover everything.

The migration or release report

Someone who was never in the laboratory must be able to read the report. The simulant has to correspond to the food type, exposure time and temperature have to match or exceed real use, and the limits applied have to be stated. The sample should carry the reference that also appears on the declaration and the purchase order. A pass with no record of what was tested, in what, for how long and against which limit is only a number.

For glass, the classic requirement is lead and cadmium release by the hollowware method. If the rim carries a fired decoration, the release question covers the decorated area as well as the bare glass.

Traceability and the extra statements retailers want

Traceability shows whether a supplier runs a controlled process. At a minimum, a finished carton should trace back to its production date, the line or furnace, and the raw material and closure lots received and used that day. A simple test: take a batch code off a carton and ask what went into it. Note whether the answer comes from a record or from memory.

Retailers also ask for statements that regulators do not require. Expect requests on animal-derived content, on allergens where the pack will touch food, on restricted substances under the general chemical regime for brands selling in Europe, and on ink migration or set-off where bottles are nested or stacked in the retail pack.

The three requests that arrive first

Whatever the market or customer, three requests lead. A supplier with all three on file can answer most onboarding questionnaires immediately.

1. The declaration of compliance, or the national equivalent. Quality departments and onboarding portals want this upload first, and its absence blocks more orders than anything else. A buyer cannot write it after the fact. Only the party that placed the material on the market can issue it. Insist that it names your article. A range-level sheet covering every bottle a plant produces has little value and is often thrown out at technical review.
2. The migration or extraction report. The reviewer wants to know whether the test conditions cover what will actually be filled. An aqueous simulant at room temperature will not satisfy someone assessing an oil-based cosmetic, a hot-filled sauce or a high-strength spirit. The report has to be current and has to describe the ordered article. A change of colour, decoration or closure can mean the old report no longer describes what ships.
3. The material and traceability statement. Composition plus batch record. This request exposes the most gaps, because here buyers find out that the closure supplier is a separate company with separate paperwork. Plants that are strong at glassmaking do not always buy from closure makers who document well.

The remedy for that third gap is to buy glass and closures as one documented pack from one responsible party where you can. If you source closures yourself, require the closure supplier's declaration and migration data when you buy, not when you ship. Whoever assembles the pack takes on the chasing, and it is better to assign that job on purpose than to discover late that nobody had it. When we coordinate a project, we collect these documents for each component against the agreed specification.

Four ways declarations get misused

Applying the plastics measure to glass

Regulation (EU) No 10/2011 is not the general food contact rule. It covers plastic materials and articles, and plastic layers inside multi-material articles. It cannot support a declaration for a glass body with no plastic food-contact layer. Where a liner, layer or coating is plastic and touches the food, the measure reaches that part and the declaration is written for that part. Accept a plastics declaration for the whole bottle and you hold paper for a fraction of the pack.

Mistaking an audit scheme for a food contact document

A food safety or quality audit scheme confirms that a management system exists. That is useful and often a purchasing prerequisite. It names no material, no article and no migration result, so it cannot discharge the food contact obligation by itself. The two complement each other. Product liability insurance and general product safety statements are likewise commercial papers, not compliance evidence.

Filing the declaration as permanent

With no expiry date on the page, declarations get filed and reused for years. Treat them as versioned. A change to the article, the closure or the decoration, an amendment to the applicable rule, or a liner material swapped without notice all call for a reissue or at least written re-confirmation. With several SKUs, keep a simple register mapping each article to its current declaration revision. The typical failure is not an absent document. It is one describing something the plant stopped making eighteen months ago.

Asking the wrong party

In many chains the plant is a contract manufacturer, and the legal duty to declare rests with the brand owner or importer who places the article on the market. The plant can normally provide the technical data and often a statement of materials used. Where the duty sits depends on the chain of placing on the market. Settle it in the purchase contract, not at the border.

Fixing a missing, mismatched or outdated document

Identify which state the pack is in before acting, because each has a different remedy.

Missing. The simplest case. Send a written request naming the article, the destination and the intended use, addressed to the party that placed the material on the market. Ask for declaration, test report and material statement in one message. Ask for one sheet and you will get one sheet, and the follow-up takes longer than a complete request would have.

Mismatched. This one tends to stay hidden until review. The declaration names a sibling bottle with another finish, the report was run on clear glass while the order is amber, or the listed cap is the previous generation. The fix is a reissue with references aligned across declaration, report and purchase order. Your part is to give all three parties exact article references instead of a verbal description. Check as well that the supplier reference on the declaration equals the one on the invoice. A difference between them is a classic trigger for a customs query.

Expired or superseded. Here the rule has moved. If the amendment alters a permitted substance list or migration limit the article depends on, the compliance position must be rebuilt, possibly with retesting. If the change is administrative, a reissue citing the current edition normally suffices. Either way, have the supplier state which edition the reissue was written against. A declaration that names its edition can be reviewed later without guesswork. One that does not gets argued over again on every order.

For goods already in transit, obtain the corrected pack before arrival and keep the correspondence proving you sought the correction before landing. Never present a document in a market it was not written for. A declaration addressed to the wrong market does more harm than none.

When the gap is in the specification, not the paperwork

A missing document sometimes says something about how the supplier is organised. Match the response to the cause.

• Exists but never requested: an administrative fix, solved by the written request described above.
• Too broad to use: a reissue naming the article, quick as long as the underlying test data exists.
• Test data absent or out of date: testing is the only fix, and it takes real money and time. Identify it before the production slot, not after.
• Undocumented closure or liner: replace the component or accept a documented change of closure. Both are commercial decisions, not compliance ones.

It becomes a true sourcing decision when the present combination of glass, closure and decoration cannot meet the requirement at all. Typical cases are an intended use beyond the tested range, such as high-alcohol or high-fat contents the migration data does not cover, or a market that demands a marking or standard the article lacks. At that point you are choosing a specification, and that choice belongs before the packaging design is frozen.

The declaration follows the specification, not the reverse. If the shape is still open, fix it first from the glass bottle and jar collections, settle the closure interface, then come back to documents. Reworking documents is cheap and reworking a mould is not. Whether the pack survives the journey is a separate question from whether it clears customs, and our drop test guide for glass bottles deals with it.

To get the requirement list for your own case, send us three facts: the destination market, the product going into the bottle, and whether it contains oil or alcohol. Those decide the simulant, the test conditions and the rule set. Add the bottle reference if you have one, or the intended use if you do not.

Frequently asked questions

Is glass exempt from food contact rules?

No. Being inert and free of any positive list of additives makes glass simpler to handle than plastic, yet it remains a food contact material. The general safety requirement, good manufacturing practice and metal release limits for lead and cadmium still apply, with release normally tested by the ISO 7086 hollowware method. Coloured, decorated and rim-decorated glass carries more of that burden.

How does a declaration of compliance differ from a test report?

A laboratory produces the test report, which records what happened to a sample under defined conditions. The party placing the article on the market signs the declaration, which states the conclusion drawn from that evidence and from any material assessment. One supports the other and neither replaces the other. A reviewer handed only the declaration will normally ask for the report.

Which document does a customs broker look for, compared with a retailer?

A retailer's onboarding team works through the three requests in order: article-specific declaration for the destination, then the migration or extraction report, then material and traceability. A broker asks something narrower. Are the goods described the same way on the declaration, the invoice and the packing list, and is the document addressed to the right market? Consistent article references across those papers prevent delays.

How long does a food contact declaration stay valid?

Validity is conditional, not time-limited. The declaration stops being current when the article, closure, liner or decoration changes, when a relevant rule is amended, or when a raw material or component is substituted without the sheet being updated. In practice, re-confirm it at least once a year and reissue it whenever one of those triggers occurs.

Can one declaration cover several markets?

It can list several markets and name the rules met in each, and for a pack sold in several countries that is common and useful. Acceptance is not automatic. Retailers often want a document written to their national expectation, and a multi-market sheet that does not say which rule set was tested against invites a follow-up question. The safe practice is one declaration per market plus a combined reference sheet.

What if the supplier cannot provide the pack?

Find out which element is missing before deciding anything. An unrequested declaration needs a specific written request. Absent test data needs testing, raised before the production slot. An undocumented closure or liner means changing the component or its source. If the article itself cannot meet the requirement, you are facing a specification decision, to be made before the design is frozen.