EU Regulation 1935/2004 Checklist for Food Contact Material Shipments

Use this checklist before you place a purchase order, bring in a new supplier, or prepare a shipment of plates, containers, packaging, or any item meant to touch food for the EU market.

1. **Confirm the product is in scope.** [EU Regulation 1935/2004](/regulations/eu-1935-2004) applies to any material or article intended to come into contact with food, including packaging, tableware, and processing equipment.

2. **Request a Declaration of Compliance from your supplier.** This document states that the material meets EU Regulation 1935/2004 requirements and should cover the specific product you are importing, not just the supplier's general line.

3. **Check that the Declaration of Compliance is current.** A declaration tied to an old product version or outdated specification is not valid for a new shipment.

4. **Identify who the Business Operator is for this shipment.** Under EU Regulation 1935/2004, the business operator is responsible for the accuracy of compliance records, and as an importer or reseller you may hold this role.

5. **Keep Business Operator records on file.** These records should show who made the product, what it is made of, and what checks were done before it was placed on the market.

6. **Set up traceability documentation.** You need to be able to show which supplier and which batch a given product came from, and where it was sent on, at every stage of the supply chain.

7. **Match documentation to the actual product received.** Paperwork that describes a different material, shape, or use than what arrived in your warehouse is a gap, not a formality.

8. **Review supplier compliance before renewing contracts.** If a supplier cannot produce a current Declaration of Compliance or clear traceability records, treat that as a reason to pause the relationship until it is resolved. See [supplier compliance](/supplier-compliance) for related steps.

9. **Store all records together and keep them accessible.** Declarations, business operator details, and traceability documentation should be easy to retrieve as a set, not scattered across separate files.

10. **Repeat this check for every new product line.** Compliance under EU Regulation 1935/2004 is specific to each material and article, so a declaration for one product cannot be assumed to cover another.

If you want help keeping these documents organized and linked to the right shipments, Complyra is worth a look.