For Southeast Asian manufacturers looking to sell on Alibaba.com and access the European market, understanding food contact material (FCM) regulations is not optional—it's mandatory. The European Union has one of the world's most stringent regulatory frameworks for products that come into contact with food, and stainless steel food containers are no exception.
The cornerstone of EU FCM regulation is Regulation (EC) No 1935/2004, which establishes the general framework for all materials and articles intended to come into contact with food [3]. This regulation applies to everything from stainless steel lunch boxes and food jars to kitchen utensils and storage containers. If your product touches food, it falls under this regulation.
- Regulation (EC) No 1935/2004: Framework regulation for all food contact materials
- Regulation (EC) No 2023/2006: Good Manufacturing Practice (GMP) requirements
- Regulation (EU) No 10/2011: Specific requirements for plastic materials (if your container has plastic components)
- National measures: Individual EU member states may have additional requirements for metals and alloys [3][4]
Under Regulation 1935/2004, all FCMs must be manufactured in accordance with good manufacturing practice (GMP) as defined in Regulation (EC) No 2023/2006 [4]. This means your production facility must have documented quality control procedures, traceability systems, and the ability to demonstrate that your products do not transfer constituents to food in quantities that could endanger human health or change the composition, taste, or odor of food in an unacceptable way.
For stainless steel products specifically, there is no single EU-wide harmonized standard. Instead, individual member states have developed their own national measures for metals and alloys. Key examples include:
- Germany: BfR Recommendation XV (metals and alloys)
- France: DGCCRF 2004-64 (metallic materials)
- Italy: Ministerial Decree of 21/03/1973 (packaging and containers)
- Netherlands: Warenwetregeling keukengerei en verpakkingsmaterialen (kitchen utensils and packaging)
When selling on Alibaba.com to European buyers, you should be prepared to demonstrate compliance with the regulations of your target markets. Many buyers will specifically request compliance with German BfR or French DGCCRF standards as these are among the most recognized.
The European Food Safety Authority (EFSA) is responsible for the scientific assessment of food contact materials. In 2025, EFSA published a literature review on microplastic migration from FCMs and re-evaluated styrene genotoxicity, demonstrating the evolving nature of FCM safety assessment [5].
The Declaration of Compliance (DoC) is a critical document that must accompany your products when placed on the EU market. This document must include:
- Your company name and address
- Product identification (type, model, batch number)
- Statement of compliance with Regulation 1935/2004 and any applicable national measures
- Information on substances subject to restrictions
- Test results or evidence supporting compliance claims
- Date of issue and authorized signature
Without a proper DoC, your products cannot legally be sold in the EU market. European buyers on Alibaba.com will typically request this document before placing bulk orders.

