Material conformity declarations: how to verify
What a material conformity declaration for food-contact use includes, how to verify it and which typical mistakes suppliers make.
A Declaration of Compliance (DoC) is a document confirming that a material is suitable for contact with food. At a HACCP or IFS audit it is required for every belt, seal and plastic part in the food zone. In this article we explain what a correct declaration must contain and how to verify it.
Why a conformity declaration is needed
Any material touching food can migrate into the product: plasticisers from a belt, paint particles, heavy metals from an alloy. Regulation EU 1935/2004 and the American FDA 21 CFR set out which substances are permitted and within which limits. A conformity declaration is the material manufacturer’s written confirmation that its product meets these requirements.
Without a declaration, equipment will not pass an audit. So we require it from every component supplier before purchase — belts, seals, food-contact lubricants.
It is important to understand the difference: a conformity declaration is a statement by the material manufacturer, backed by test results, not a certificate issued by a state body. Responsibility for accuracy lies with whoever signed the declaration. So the wording and specifics in the document matter: a vague declaration is legally weak and will not pass a serious audit.
What a correct declaration must contain
A proper declaration is not just the phrase “suitable for food contact”. It contains a specific set of data:
- Material identification — exact grade, article number, composition.
- A reference to the regulation — EU 1935/2004, EU 10/2011 for plastics, FDA.
- Conditions of use — temperature, product type, contact time for which they are valid.
- Migration test results — overall and specific migration.
- The date and signature of the manufacturer’s responsible person.
| Declaration element | Why to verify |
|---|---|
| Material grade | must match what is actually supplied |
| Regulation | EU 10/2011 — specifically for plastics |
| Temperature range | the declaration is valid only within it |
| Product type | aqueous, acidic, fatty — different migration limits |
| Issue date | an outdated declaration may be invalid |
Migration tests: overall and specific migration
The core of a declaration is the migration test results. Overall migration (Overall Migration Limit, OML) shows the total mass of all substances passing from the material into a food simulant; the limit under EU 10/2011 is 10 mg per dm² of surface or 60 mg per kg of product. Specific migration (SML) sets a separate limit for each potentially hazardous substance — plasticiser, monomer, colourant.
Tests are run on food simulants: distilled water for aqueous products, 3% acetic acid for acidic ones, ethanol and vegetable oil for fatty ones. That is exactly why the product type matters in the declaration: a belt safe for contact with dry vegetables may exceed the migration limit in a fatty medium. A correct declaration always states for which simulant and at what temperature the tests were carried out.
Typical supplier mistakes
Over the years we have seen recurring problems with declarations:
- A declaration for another grade. The supplier provides a document for belt A but delivers belt B.
- A mismatched temperature range. The declaration is valid up to +40 °C, but the line runs at +90 °C.
- A generic phrase without data. “Meets the requirements” with no reference to a regulation or tests.
- An expired document. An old declaration for a material whose formula has already changed.
Engineer’s tip. Verify not only the presence of a declaration but also that the conditions of use match your process. The most common mistake is a belt with a correct declaration, but one issued for cold contact, fitted to a hot-fill line. Formally the document exists; in fact it is invalid for your regime.
How we work with documentation
On our projects the conformity declaration is part of the line’s document set together with equipment passports. We keep declarations for all contact materials and hand them to the customer — a ready evidence pack for the auditor.
We also advise keeping a register of contact materials: a list of all belts, seals and plastic parts of the line tied to specific declarations. When a supplier changes a material’s formula or you fit a new belt, the register immediately shows which declaration needs updating. Without such a register it is easy to lose track on a large line — and discover a gap only at the audit. For more on audit preparation, see the articles tagged standards, and on material choice — the material on conveyor belts.
Not only materials but also construction
A conformity declaration covers the material, but an auditor looks wider — at how that material is applied. A belt with a flawless declaration, fitted with an open edge cut where product packs in, or in a zone with a blind pocket not cleaned during washing, creates a risk despite the document.
So we accompany declarations with a description of design solutions: radius transitions instead of sharp corners, no uncleanable cavities, belt fastening materials also with a food approval. At an audit it is important to show not just the paper for the belt but the logic of the whole food zone — how it is washed, where product can accumulate, what confirms the safety of joints. A full evidence pack is declarations plus competent construction.
Conclusion
A conformity declaration is not a formality but a working document that must precisely describe the material and its conditions of use. Verify the grade, regulation, temperature range and product type — and demand the declaration before purchase, not at the audit. Need advice on line documentation? Get in touch — we’ll help assemble a correct pack.
