FCM Certification Repeatedly Rejected? Must-Read Compliance Checklist for Sellers

If you sell Food Contact Materials (FCM) products,passing FCM document review is an inevitable requirement.Many sellers keep getting their test reports rejected due to trivial oversights.This not only delays product listing but also wastes extra time and cost on retesting and document rearrangement.

To help you pass FCM certification submission smoothly and avoid rework, we have sorted out the most common review rejection issues encountered in daily service cases.https://www.huak-cer.com/industry/household-product-testing/ 

Follow this self-check guide to steer clear of most audit pitfalls and get approved on the first try.

Key Strict Audit Details for FCM Food Contact Material Certification

Food Contact Materials are directly related to food safety,so platforms and regulatory authorities conduct extremely strict reviews on test reports.Every detail in the report—sample information,material description,test items,and test methods—must fully match the actual sold products.Any slight discrepancy will lead to rejection.Please pay close attention to the frequent problems below.

FCM Audit High-Frequency Rejection Reasons

1. Missing color testing — only one color tested for multi-color products

Many food-contact items come in multiple colors,such as multi-color silicone tableware,colored plastic kitchenware,multi-color stainless steel cutlery under the same SKU.However,some sellers only submit a test report for one single color while other color variants remain untested.

This does not meet compliance requirements.All color versions under the same SKU must be fully tested accordingly.A single-color test report cannot cover all styles and will be directly rejected.

2. Tested sample inconsistent with actual selling products

This is the top reason for rejection.Example:The report tests "silver stainless steel fork",while you actually sell a "black tableware set" that does not appear in the test sample photos.Product name,style,and specification do not match the listing goods at all.

The tested sample must be identical to your officially listed products in name,style,specification and combination set.It is not allowed to replace with reports of similar products.

3. Vague material labeling without specific material grade

Some reports only mark the material generally as "Plastic" without specifying exact types such as PP,ABS,PET,Silicone,etc.

Different food-contact materials have vastly different test standards and mandatory items.Vague labeling cannot prove compliance with the corresponding material regulations.A formal qualified report must clearly state the exact material type and match the relevant testing standards for verification approval.

4. Incomplete coverage of food-contact parts — missing key contact areas

For combined kitchenware and tableware sets,missing tests on contact parts is very common.Example:For cookware sets,only the metal pot body is tested,while food-contact parts like glass lid,metal nuts on handles, inner gaskets are ignored.For tableware sets,only the main body is tested while accessories and edge contact areas are left uninspected.

All direct and indirect food-contact components must be fully covered in testing without omission to ensure overall compliance.

5. Metal products missing OM Overall Migration test

In accordance with Resolution CM/Res(2020)9,metal food contact materials are mandatorily required to complete OM (Overall Migration) testing.Many sellers overlook this essential item when submitting metal products, resulting in incomplete reports and audit failure.

6. Incomplete test items for specific materials — failing compliance checklist

Each material has its own mandatory test items.Take common ABS plastic as an example,besides basic tests,the below core items are compulsory:

• Residual 1,3-Butadiene

• Specific Migration of Acrylonitrile

• Specific Migration of Primary Aromatic Amine (PAA)

• Specific Migration of 1,3-butadiene

• Total BPA content (only for products intended for children under 3 years old)

Missing any single item will be judged as incomplete testing and rejected.

7. Wrong test method adopted for Metal OM Overall Migration

Even with complete test items,an incorrect test standard invalidates the report.Overall migration testing for metal products shall follow Italian DM 21/03/1973.Some sellers mistakenly apply EN 1186 (plastic standard) for metal testing;mismatched test methods will not be recognized by auditors.

8. Incorrect standard for VCM Visible Colour Migration

Visible Colour Migration (VCM) follows different standards by material:

• Plastic materials:comply with AP(89)1 & 1935/2004/EC

• Silicone materials:refer to LFGB requirements

Mixing up standards will render the test report non-compliant and invalid.

How to Pass FCM Certification Submission at One Time

1. Double-check sample style,color,material and specification before sample sending —keep fully consistent with listed products.

2. Mark material type precisely;avoid general and vague descriptions.

3. Test all food-contact parts with full coverage, no missing components.

4. Adopt correct test items and test methods strictly according to material-specific standards.

5. Cooperate with an official accredited third-party lab to issue authoritative, audit-compliant test reports.

Food contact material compliance leaves no room for negligence.A complete and standardized FCM test report is the core guarantee for smooth listing and legal sales.

If you have any questions about sample testing,certification submission or report rectification,feel free to contact us.With professional testing capabilities,we can customize exclusive compliance solutions for your products,helping you pass audits efficiently and operate business without compliance worries.

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