Getting Your Food Contact Declaration of Conformity (DoC) Right

What is a DoC?

A Declaration of Conformity (DoC) is a signed statement from whoever made your product's food-contact material, confirming that it has been checked and is safe and legal to use with food under UK and EU rules. Think of it as the paper trail that proves your material has been assessed — not just described as ‘food safe’ on a spec sheet.

If any part of your product touches food or drink — directly or indirectly — you need a DoC for that part. This includes obvious items like food storage containers, cutlery, bakeware and drinking bottles, but also easy-to-miss components such as a lid seal, a straw, an inner packaging film, or a coating inside a can or jar.

Why it matters?

Without a valid DoC on file, a product can be blocked at customs, removed from a marketplace listing (Amazon and other platforms increasingly ask for this documentation directly), or flagged during a compliance check once it is already on sale. Getting the DoC right before launch is far more straightforward than fixing it after the fact.

Do I need a DoC for my product?

Ask yourself one question for each material in your product:
The quick test

‘Does this part of my product touch food or drink, or could it reasonably come into contact with food during normal use?’ If the answer is yes for any material — even a small component — that material needs its own DoC.

· Food storage containers, lunch boxes, drinking bottles and cups

· Bakeware, cookware and kitchen utensils

· Cutlery, plates and tableware

· Lids, seals, gaskets and straws

· Packaging that sits directly against food (bags, films, liners)

· Any coating on the inside of a can, jar or flask

If your product has several materials — for example, a plastic body, a silicone seal and a metal lid — each material needs its own DoC. This is one of the most common gaps we see: clients hold a DoC for the main body of the product but not for the seal or lid.

Step by Step: How to Get Your DoC

01 List every food-contact material in your product

Go through your product piece by piece and note down each material that touches food: the body, the lid, any seal, any coating. Treat each one separately — they each need their own paperwork.

02 Ask your factory or supplier for their existing DoC

Most factories that already export to the UK or EU will have a DoC on file for the materials they use. Ask for it by name — ‘Declaration of Conformity’ or ‘Declaration of Compliance’ — rather than just asking if the material is ‘food safe’, which is not the same thing and is not enough on its own.

03 Check the DoC actually matches your product

A valid DoC should name the specific material and, ideally, the specific product or part — not a generic template covering the whole factory's product range. If it looks generic, ask your supplier to confirm in writing that it applies to your exact material and specification.

04 Confirm it is dated, signed and complete

It should show who issued it, when, and a clear statement that the material complies with the applicable UK or EU food contact law (see the checklist below).

05 If your supplier cannot provide one, arrange testing

This means sending a sample of the material to an independent, accredited laboratory, which checks that nothing harmful transfers from the material into food (this is called migration testing). This produces the evidence a proper DoC is then based on.

06 Keep it on file and update it if anything changes

If you change supplier, change material, or the factory changes how the product is made, the old DoC no longer applies and a new one is needed.

07 Share it with Expandly for review

Send us the DoC alongside your product details. We check it against the checklist below, flag any gaps, and let you know what (if anything) still needs to be resolved before you list the product.

What should a good DoC include?

Use this as a checklist when you receive a DoC from a supplier. A properly completed DoC should show:

Red Flags: When to Push Back on a Supplier's DoC

· It is a generic, one-page document with no reference to your specific material or product

· It is undated, or clearly reused from an old order

· It only says the material is ‘food safe’ or ‘FDA approved’ without naming any UK or EU law (US approval does not cover UK/EU requirements — these are separate regimes)

· It has no contact details for the issuing company, or the company name does not match your actual factory

· It covers a different material, colour, or grade to the one actually being supplied

If you spot any of these

Do not rely on the document as-is. Go back to your supplier and ask for a corrected, product-specific version, or treat this as a signal to arrange independent testing instead. This is a normal and expected part of onboarding a new supplier — most reputable factories will be able to sort this out quickly once asked.

Template: Requesting a DoC from Your Supplier

You are welcome to copy and adapt the wording below when contacting a supplier.

Sample email

Subject: Food Contact Declaration of Conformity – [Product name / reference]

Hi [Supplier contact name],

For our UK/EU product listings, we need a Declaration of Conformity (DoC) for each food-contact material used in [product name / reference]. Could you please send us:

1. The current DoC for [material, e.g. the plastic lid / silicone seal], specific to this product
2. Confirmation of the date it was issued and whether anything has changed since
3. A copy of the underlying migration test report, if available

If a DoC is not currently available for this material, please let us know so we can arrange independent testing.

Thank you,
[Your name]

What If My Supplier Can't Provide One?

This is common, especially with factories that are new to exporting into the UK or EU. You have three options:

01 Ask your supplier to obtain it from their own raw material supplier

The DoC often needs to come from further up the supply chain (the resin or pellet manufacturer, for example), not just the factory that moulds the final part.

02 Commission independent testing directly

You send a sample to an accredited laboratory yourself. This gives you the most control and your own evidence, independent of the supplier.

03 Ask Expandly to help source an accredited lab

We can point you toward a laboratory suited to your material and intended food use, and review the resulting report once it is issued.

A Few Terms You Might Come Across

MOCA: You may see this on paperwork from Italian suppliers. It is simply the Italian term for ‘food contact material’ — it refers to the material itself, not a different type of document. A ‘MOCA declaration’ is the same thing as a DoC.

“Food safe”: A marketing phrase, not a legal one. It is not a substitute for a proper DoC and should not be accepted as evidence on its own.

“BPA-free”: A useful claim, but it does not confirm compliance with everything else the material needs to meet. A full DoC is still required.

“FDA approved”: Confirms US compliance only. It does not carry across to the UK or EU, which have their own separate rules and their own DoC requirement.

How Expandly Helps

· We review the DoCs your suppliers provide, using the checklist in this guide, before your product goes live

· We flag gaps or red flags and tell you exactly what to ask your supplier for

· We can point you toward accredited testing labs if a DoC cannot be obtained

· We keep your compliance documentation organised and versioned against your product listings

What stays with you and your supplier

Expandly compiles and reviews this documentation on your behalf, but does not itself test products or sign a Declaration of Conformity. That responsibility sits with your manufacturer (who has first-hand knowledge of the material) and with you as the business bringing the product to market.

Our role is to make sure you have what you need, and that it is genuinely fit for purpose, before you rely on it.

Questions about a specific product or supplier document? Send it across and we will review it against this checklist.