Regulations

Exporting laminated molded-fiber trays to the EU — which food-contact checks apply?

Three things matter: resin/film under (EU) 10/2011 and fiber side under applicable rules, OML and SML migration within limits, and a supporting Declaration of Compliance plus test reports.

food contactEU 10/2011DoCmigrationEU exportregulation

Short answer

For food-contact molded-fiber trays exported to the EU: the film/resin must meet (EU) 10/2011, the fiber substrate the applicable paper rules, the finished article must pass OML/SML migration, and you need a complete DoC with supporting test reports.

Key regulatory layers

LayerRegulationFocus
Film (plastic)(EU) No 10/2011monomers, additives, SML
Fiber substratepaper rules / (EC) 1935/2004heavy metals, etc.
Finished article(EC) 1935/2004overall migration OML

Three must-meet items

1. OML (overall migration) within limit (often 10 mg/dm²). 2. SML (specific migration) per restricted monomer within limit (10/2011 Annex I). 3. Upstream raw-material compliance info to build the DoC.

What a DoC must contain

Manufacturer/importer identity; material and legal basis (10/2011, 1935/2004); test conditions & results (temperature/time/food simulants); use limits & food-type applicability; signatory and date.

Practical notes

Choose food simulants per intended use conditions; importers/brands usually demand a full DoC and technical file; assess the film-to-fiber interface, not only the film.

Data & limits

Regulations update (10/2011 amendments, new monomers). Verify against the latest official text and a notified body before export.

FAQ

What EU rules apply to fiber trays?

Film/plastic under (EU) 10/2011; fiber substrate and overall migration under (EC) 1935/2004 and applicable paper rules; plus a DoC and test reports.

What are OML and SML?

OML is overall migration (total released by the article); SML is specific migration of a single restricted substance. Both must stay within limits under the relevant conditions.

A customer asks for a DoC — how do I issue one?

Build it from supplier raw-material compliance plus your finished-article migration results, stating legal basis, test conditions, use limits and signature. Have an expert body review.

Will EU accept a Chinese test report?

Only if tests follow EU methods/simulants and the lab is recognized in the EU. Prefer an EU-recognized or notified-body report.

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