Compliance · Nº 02 · European Union
EC 1935/2004
EU food-contact materials framework
Applies to — Labels & adhesives on food packaging sold in the EU
EC 1935/2004 is the EU framework for any material that may contact food — not a single material type. It requires that, in normal use, materials do not transfer their constituents to food in harmful amounts or unacceptably change its taste, colour, or composition, and that labelling is not misleading. Food-contact items must carry “for food contact” or the glass-and-fork symbol, and materials under specific measures (such as plastics under EU 10/2011) need a Declaration of Compliance.
What it covers
It is a framework regulation, not a material spec — it applies to any material or article intended to come into contact with food, including label facestocks and adhesives that may reach the food. The core principle: under normal, foreseeable use, the material must not endanger health, change the food’s composition unacceptably, or alter its taste, smell or colour.
Who needs it
Any brand selling food or beverage products into the EU. If a label adhesive or facestock could contact the food — or the packaging structure allows migration — it must be able to provide an EC 1935/2004 declaration. This runs alongside, not instead of, national rules and any product-specific measures.
What it requires
Three practical things: (1) materials must not transfer constituents to food in harmful amounts or unacceptably change taste, colour or composition; (2) food-contact items must show “for food contact” or the glass-and-fork symbol; (3) materials covered by specific measures — plastics under EU 10/2011, for example — require a Declaration of Compliance (DoC) documenting conformity.
How to comply
Ask your supplier whether the label adhesive and facestock can provide an EC 1935/2004 declaration, and a DoC where a specific measure applies. Because 1935/2004 is a framework, the exact evidence depends on the material and the food type — confirm the specific declaration your product and market require rather than treating “EU compliant” as one-size-fits-all. US-market food labels additionally follow FDA 21 CFR.
Common questions
Answered
straight.
What is EC 1935/2004?
The EU framework regulation for any material that may contact food. It requires that materials not transfer constituents to food in harmful amounts or unacceptably change its taste, colour or composition, that food-contact items are marked accordingly, and that materials under specific measures carry a Declaration of Compliance.
Do EU food labels need a Declaration of Compliance?
Materials covered by specific measures — for example plastics under EU 10/2011 — require a Declaration of Compliance. Ask your supplier whether your label adhesive and facestock can provide an EC 1935/2004 declaration and a DoC where applicable.
Is EU food-contact the same as FDA?
No — they are separate frameworks. Food labels sold in the EU follow EC 1935/2004 (plus any specific measures); US-market labels follow FDA 21 CFR. If you sell into both, meet both.
General guidance — not legal advice
This is a plain-English overview to help you ask the right questions — not a legal opinion or a compliance certification. Requirements change and depend on your specific product, market, and packaging. Always confirm with your supplier’s compliance documents and, where it matters, a qualified regulatory advisor.
Official source · EUR-Lex — Regulation (EC) 1935/2004 ↗
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