Food-grade certification (EU 10/2011) explained 

Regulation (EU) No 10/2011 is the European legislation governing plastic materials that come into contact with food. The regulation specifies which substances are permitted and the maximum amounts that may migrate into food. Plastic crates used for food must comply with these requirements. 

What the regulation covers 

EU 10/2011 is known in the sector as the Plastics Regulation. The regulation contains a Union list of authorised monomers and additives for food-contact plastics. 

Only substances on that list may be incorporated into the material. Furthermore, restrictions on concentration or use apply to many substances. 

The regulation falls under Framework Regulation (EC) 1935/2004. This sets out the general requirement that materials must not adversely affect food safety, composition or taste. 

Migration limits: the essence of food-grade 

Migration is the transfer of substances from the packaging into the food. EU Regulation 10/2011 limits this migration through two types of limits. 

The total migration limit is set at 10 milligrams per square decimetre of contact surface area. In addition, specific migration limits apply to each substance, based on toxicological assessment. 

Laboratories test migration using simulants that mimic food groups, such as aqueous, acidic, alcoholic and fatty foods. The test conditions replicate actual use, including temperature and duration of contact. 

The Declaration of Compliance 

Every link in the chain must be able to provide a Declaration of Compliance. This document confirms that the material complies with EU Regulation 10/2011. 

The declaration specifies, amongst other things, the suitable food types, the contact conditions and the substances for which a specific limit applies. This enables you, as a customer, to assess whether a crate is suitable for your application. 

Always ask for this document when purchasing food-grade crates. Without the declaration, you cannot demonstrate compliance during an audit or inspection. 

How to recognise food-grade material 

The best-known feature is the glass-and-fork symbol on the product or in the documentation. This symbol indicates that the material is intended for contact with food. 

However, the symbol alone is not proof. The evidence lies in the declaration of conformity and the accompanying migration test reports from an accredited laboratory. 

You should also check the base material. PE, HDPE and PP are the standard food-grade plastics used for crates: non-porous, odourless and resistant to cleaning agents. 

Food-grade standards and production hygiene go hand in hand 

In addition to the material requirements, Regulation (EC) No 2023/2006 on good manufacturing practices (GMP) for food contact materials applies. This requires manufacturers to have a documented quality assurance system. 

A food-grade raw material can still become unsuitable due to contamination during production or storage. GMP ensures that the end product is just as safe as the material is on paper. 

Common mistakes in procurement 

The biggest pitfall is relying on the term ‘food-grade’ in a product description. Without a declaration of conformity, that term is merely commercial jargon, not proof. 

A second mistake is overlooking the colourant. The base plastic may be fully compliant, whilst a masterbatch or pigment contains substances not included on the Union list. 

Finally, check the date and scope of the documents. A declaration should be up to date and refer to the product supplied, not to a comparable model from an older series. 

What this means for crates in the food industry 

For crates in direct contact with meat, fish, bread or fruit and vegetables, food-grade material is the standard, not an optional extra. Check that the raw material and the colourants used are on the EU list. 

Also bear in mind reuse. Reusable crates go through many washing and usage cycles; the material must withstand this stress without any change in its migration behaviour. 

Recycled material in food contact requires extra attention. Since Regulation (EU) 2022/1616 came into force, separate rules apply to recycled plastic in contact with foodstuffs. 

Finally, take the conditions of use into account. A crate suitable for dry bread at room temperature is not automatically suitable for fatty meat or hot fillings; the declaration of conformity explicitly states these limits. 

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