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What is the FCM Declaration of Conformity (DoC) for the Chinese market?

The Declaration of Conformity is crucial in every step of the supply chain when producing food contact materials for the Chinese market.

What is the FCM Declaration of Conformity (DoC) for the Chinese market?

One of the key documents for indicating compliance on the Chinese market is the declaration of conformity (DoC). This document must be available at each stage in the supply chain and forwarded from supplier, to intermediate manufacturer, and to end customer of food contact materials in order to verify compliance at each step of production. The DoC ensures that all components and production steps in the manufacture of food contact material can be used in accordance with the food contact regulations, thus ensuring product safety for consumers.

Why is a DoC necessary?

In China, a set of regulations for Food Contact Materials (FCM) and food contact products has been established, which includes numerous standards for FCM. It defines regulatory compliance responsibility along the supply chain, prescribes sensory, physical, and chemical specifications, and regulates raw materials and additives, and intermediate materials intended to come into contact with food. Restrictive requirements are also defined, limiting things like Specific Migration Limits (SML), SML (T) and maximum allowed quantities (QM) in raw materials and additives.

Responsibilities of supply chain


In order to be able to ensure the product safety of their own product, processing institutions are obliged to keep not only their own DoC, but also those of their suppliers or manufacturers of intermediate products, and to be able to present them in the event of inspections. In addition, not only is the regulatory compliance and the safety of the individual ingredients checked, but also the correct processing and production steps are documented. In order to ensure product safety, the various stakeholders have different areas of responsibility:

  • FCM substance manufacturers provide the DoC of food contact substances and ensure that the quality specifications meet the regulatory requirements
  • Intermediate material manufacturers provide the DoC of substances/materials used/added and produced in the process and verify the DoC from manufacturers upstream. They also transfer their own DoC downstream.
  •  Final food contact product manufacturers are responsible for the raw materials (food contact substances), intermediate materials, added FCM substances and generated substances in the production process, and confirm that the FCM materials and food contact substances meet the regulatory food contact requirements. They are obligated to obtain the relevantdocuments from manufacturers upstream and ensure the correct use in the final product.  They will share their DoC with final food contact product users. They also provide consumers and distributors with information on the expected use of the FCM.
  • Consumers are advised to abide by the instructions on the commodity label, and correctly use the food contact product.
  • Distributors are obliged to store and transport FCM as required by the supplier and must release DoC to their customers.

Check our download on the Declaration of Conformity, or contact the knoell FFCM team to get their insight on your regulatory needs.