Food contact materials: importing kitchenware from China
Plastic kitchenware from China needs a declaration and a laboratory report before it can be imported. What is tested, and the limits that matter.
Kitchenware from China gets extra scrutiny
Polyamide (nylon) and melamine plastic kitchenware and tableware originating in or consigned from China and Hong Kong faces a specific import control in Great Britain: the importer has to provide a declaration and a laboratory report showing the goods meet limits on the release of certain harmful chemicals. Other plastics — PP, PET, silicone and the rest — are not caught by this import regime, though they still have to meet the general food-contact rules.
This sits on top of the general rule that any material intended to touch food must not transfer its constituents into food in amounts that could endanger health, unacceptably change the food's composition, or spoil its taste, smell or appearance. Note this import control applies in Great Britain; Northern Ireland follows EU rules under the Windsor Framework, with a different notification route.
The two limits that come up most
For melamine articles, the substance of concern is formaldehyde, with a release limit of 15 mg per kg of food. For polyamide (nylon) kitchenware — spatulas, tongs, slotted spoons — it is primary aromatic amines, and here two different figures apply. The import control uses a detection threshold of 0.01 mg per kg. But to be lawfully sold, the carcinogenic PAAs must not be detectable at all, using equipment with a limit of detection of 0.002 mg per kg for each individual amine; the 0.01 mg per kg figure survives only as a combined limit for the other PAAs.
Those two account for most of the failures on kitchenware from China, and they are exactly the products a UK catering or homeware buyer is likely to be importing.
The declaration of compliance
A written declaration of compliance is mandatory for the material groups that have specific rules — plastics, ceramics, regenerated cellulose film, active and intelligent materials and recycled plastics — at every marketing stage before retail. For paper, rubber, metals and other unharmonised materials there is no statutory declaration, but you should still require equivalent written evidence. For Great Britain the declaration must attest compliance with the assimilated GB regulations: GB and EU requirements have begun to diverge, so a declaration written only against EU law no longer proves GB compliance.
Supporting documentation has to back the declaration up: the test report, the material composition, and any restrictions on use such as maximum temperature, whether the item is microwave or dishwasher safe, and whether it is intended for repeated use.
Test the goods you are actually buying
A report on a different colour, a different resin batch or a different factory is not evidence about your order. Colourants and fillers change migration behaviour, so a black nylon spatula is not covered by a report on a red one from a different run.
Commission testing from an accredited laboratory on samples taken from your production, and keep the report with the shipping documents so it can be produced on request.
Building it into the order
Set the intended use in the specification — hot food, microwave, dishwasher, repeated use — because that determines the test conditions. Then test against that use, not against a generic scenario.
We specify food-contact requirements before quoting, arrange testing on production samples, and check that the declaration cites UK legislation, so the goods clear on documentation rather than being held.
Frequently asked questions
Do I need a lab report to import kitchenware from China?
For polyamide (nylon) and melamine kitchenware originating in or consigned from China or Hong Kong, yes: the importer has to provide a declaration and a laboratory report confirming compliance with the release limits. Other plastics are outside this import control.
What are the limits for melamine and nylon kitchenware?
Formaldehyde release from melamine articles is limited to 15 mg per kg of food, and primary aromatic amines from polyamide (nylon) kitchenware to 0.01 mg per kg of food.
Can I use my supplier's EU declaration?
It is not sufficient on its own. A declaration of compliance for the UK market should cite UK legislation, and a declaration referencing only EU regulations is a common defect in factory paperwork.