Declaration of Compliance – what information is obligatory?

Declaration of Compliance – what information is obligatory?

According to the European Framework Regulation EC 1935/2004 on all food contact materials, suppliers of conveyor belts for the food industry should provide customers with a Declaration of Compliance (DoC) in order to confirm that their products comply with the applicable European directives.

Since a DoC contains an extensive amount of data, it can be complicated to identify which information is and is not necessary. In this post, I will clarify which details must be included in a DoC.

The Requirements

  • Address and identity of the manufacturer
  • Identification of the materials and/or items
  • Date of the declaration
  • Confirmation of compliance with (EC) No. 1935/2004
  • Adequate information about migration restrictions / specifications of substances
  • Adequate information about substances with food additive restrictions
    Specifications concerning the use of material (food types, temperature, time, min. food/space ratio)
  • Presence of recycled plastic (registration number)

The information given below is not included in a DoC:

  • Migration values
  • Ending date of the declaration (not obligatory)

Migration values

I am often asked about the provision of the migration values of our conveyor belts. It is sometimes thought that food processing companies must provide the migration values in order to comply with the food safety standards (BRC, IFS, ISO 22000 en FSSC 22000), but according to the European rules, none of the food safety standards require provision of the migration values of a conveyor belt.

Regulation (EU) No. 10/2011, a specific plastics directive within Regulation (EC) no. 1935/2004, states that “documents” (migration values, etc.) are explicitly intended for the regulatory authorities. A conveyor belt shall comply with the European rules and a Declaration of Compliance must be drawn up for this.

Lately, we have received a number of inquiries about how Habasit deals with the new COMMISSION REGULATION (EU) 2016/1416 of 24 August 2016 amending and correcting Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food. Regulation (EU) No 2016/1416 is not a new regulation but one of eight amendments to regulation 10/2011. Habasit’s Declaration of Compliance for food contact materials always refers to the latest update of this regulation.

Within the recent updates, manufacturers are also given the necessary time to adapt their products to the new requirements. Without this transition, products would become illegal within 20 days after the publication of the amendment.

Status at Habasit

As one regulation is often referring to another in these documents, this can lead to some uncertainty, but rest assured that all Habasit food belts comply with the currently applicable rules. I keep a close track of any changes and will be quick to inform Habasit employees of any relevant information.

Do you require additional information? You can download the brochure or contact me through expert.blog@habasit.com.

 

2017 November 28  |  Posted by

Markus Hilfiker

Markus Hilfiker is a Regulatory Officer at Habasit and has been with the company for the last two decades. He specializes in the knowledge and implementation of product and application related regulations and is responsible for the safe use of chemicals at our Reinach location. He is fluent in both German and English.

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