How to Obtain a Declaration of Conformity for Drinkware Exports to the EU

If you are planning to export drinkware—such as aluminum water bottles or stainless steel tumblers—to the European Union, you will likely need a Declaration of Conformity (DoC). This document is a legal requirement for many products, including food contact materials. In this article, we explain what a DoC is, why it is necessary, who should issue it, and the steps to obtain one.

What is a Declaration of Conformity?

A Declaration of Conformity is a formal document in which the manufacturer or importer declares that a product complies with all applicable EU directives and regulations. For drinkware, the most relevant regulations include:

• Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food
• Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food
• Specific measures for certain materials, such as Regulation (EU) No 10/2011 for plastics (if applicable)
• General Product Safety Directive (GPSD) 2001/95/EC, replaced by the General Product Safety Regulation (GPSR) 2023/988

The DoC must list the product, the manufacturer, the applicable legislation, and the standards or test reports used to demonstrate compliance. It must be signed and dated.

Why is a DoC Needed for Drinkware?

Drinkware comes into direct contact with beverages, so it is considered a food contact material. EU law requires that such materials do not transfer harmful substances into food or drinks in quantities that could endanger human health. A DoC provides assurance to importers, retailers, and market surveillance authorities that the product meets these requirements.

Without a DoC, your shipment may be detained at customs, and you may face fines or forced withdrawal from the market. Having a valid DoC is essential for smooth market access.

Who Should Issue the Declaration of Conformity?

Under EU rules, the responsibility for compliance lies with the manufacturer. If the manufacturer is outside the EU (for example, in China), the importer established in the EU becomes responsible for ensuring compliance and may need to issue the DoC. In practice, the manufacturer often drafts the DoC based on test reports and technical documentation, and the importer can then sign it or issue their own version.

For drinkware, the DoC should be issued by:

• The manufacturer, if they are based in the EU, or
• The importer or authorized representative in the EU, if the manufacturer is outside the EU.

It is important that the entity signing the DoC has the technical documentation to back up the claims.

How to Get a Declaration of Conformity for Your Drinkware

Obtaining a DoC involves several steps. Here is a practical guide:

1. Identify the applicable regulations. Determine which EU laws apply to your specific drinkware. For aluminum and stainless steel bottles, the general food contact regulation (EC) 1935/2004 applies. If there are plastic components (e.g., lids, seals), Regulation (EU) 10/2011 may also apply.
2. Gather material information. Ask your manufacturer for detailed material specifications, including any food-grade certifications or migration test reports. For example, if you are sourcing a product like the 17oz Triangular Aluminum Water Bottle with Carabiner Outdoor (model FL-551A) from Sensialu, you can request information about the 99.7% pure aluminum used and any testing conducted.
3. Conduct compliance testing. Work with an accredited laboratory to perform migration tests and other relevant tests. The tests should simulate the intended use (e.g., contact with water, acidic drinks, etc.) and ensure levels of heavy metals and other substances are within legal limits.
4. Compile a technical file. This file should include product descriptions, material declarations, test reports, and a risk assessment. Keep this file for at least 10 years after the last product was placed on the market.
5. Draft the Declaration of Conformity. The DoC must contain:
   • The name and address of the manufacturer or importer
   • Identification of the product (model, batch, etc.)
   • A list of applicable EU legislation
   • References to the standards or test reports used
   • The date and place of issue
   • Signature and title of the responsible person
6. Sign and date the DoC. The responsible person must sign the document. It should be made available to authorities upon request and supplied to your customers.
7. Maintain compliance. Keep records updated and re-test if materials or production processes change.

The Manufacturer's Role in the DoC Process

Your manufacturer plays a key role in providing the necessary information for the DoC. A reliable manufacturer will be able to supply material safety data sheets, test reports, and declarations of compliance for raw materials. When choosing a supplier, look for one that understands EU regulations and can support your compliance efforts.

Sensialu, operated by WUYI SENSI INDUSTRY & TRADING CO., LTD., is a professional manufacturer of custom aluminum water bottles and stainless steel drinkware. They offer OEM and ODM solutions for global brands, retailers, and promotional markets. If you are sourcing drinkware for the EU, you can contact them to discuss your compliance needs and request the product information required for your DoC.

For example, the 17oz Triangular Aluminum Water Bottle with Carabiner Outdoor (model FL-551A) is made from 99.7% pure aluminum. You can request relevant material declarations from Sensialu to support your compliance documentation. You can reach them at [email protected] or call +86 15024587743. Their address is Gumashan Industrial Area, Wuyi, Zhejiang, China.

Conclusion

A Declaration of Conformity is a critical document for exporting drinkware to the EU. It demonstrates that your products meet food contact safety requirements and helps you avoid customs delays and legal issues. The DoC should be issued by the manufacturer or the EU importer, based on thorough testing and documentation. By working closely with your manufacturer, such as Sensialu, you can gather the necessary information and ensure a smooth compliance process.

For more information on their products, visit https://www.sensialu.com/17oz-outdoor-aluminum-water-bottle-with-carabiner.