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FDA, LFGB and EN71: What Buyer-Side Certification Actually Covers

   2026-10-20 OriginalChina Plastic Factory Editorial130
Summary: A buyer-side guide to the certification marks that appear on plastic consumer goods quotations: what each standard covers, which documents a supplier can legitimately provide, and where the usual gaps appear.

Certification language on a quotation is often copied from one enquiry to the next, and the result is that buyers receive certificates that do not match their product or their market. This guide sorts the marks that matter for moulded plastic consumer goods and explains which documents a moulding plant can honestly provide.

Food contact: FDA and LFGB are declarations, not product certificates

FDA 21 CFR and LFGB are frameworks under which the material is assessed. A resin producer can test its PP grade and issue a food contact statement for that grade; a moulding plant can declare that it moulds that grade in machines dedicated to non-hazardous materials. Neither can certify the finished bowl on its own, because the finished product also includes colour masterbatch, mould release agent and any printing ink. What a buyer should collect is: the resin or compound food contact statement, the masterbatch declaration, a moulding plant declaration covering machine and handling practice, and, for the EU, migration testing of the finished article commissioned by the buyer. The certification guides that stop at a resin certificate are incomplete.

EN71 and ASTM F963 for toys

EN71 is a series, not a single test. EN71-1 covers mechanical and physical properties, EN71-2 flammability, EN71-3 the migration of nineteen heavy elements. ASTM F963 is the US equivalent with its own scope and limits, and CPSIA adds tracking labels, lead and phthalate limits for the US market. Compliance is assessed on the finished toy as sold, which means every colourway, every decoration and the packaging. A supplier that quotes EN71 for the base polymer and not the decorated part has quoted the wrong article.

For moulders, the practical consequence is that the same base part can be compliant in one colourway and non-compliant in another, because the element migration comes from the pigment. Programmes with many colourways should budget for one migration test per colour family rather than per colour, and should keep the pigment supplier declaration on file so a re-tested masterbatch can be swapped in without re-testing the whole toy.

REACH, RoHS and the rest of the CE stack

REACH is a chemical registration framework: the obligation that reaches a buyer is SVHC communication. If an article contains a substance on the candidate list above 0.1 percent, the supplier must tell the buyer, and the information has to be available down the chain. RoHS applies to electrical and electronic products, which in this catalogue means the rechargeable and battery-powered items such as massager housings and remote control transmitters. CE marking on a finished device is the assembler's responsibility; a moulding plant supplying housings contributes RoHS-compliant material declarations and cannot CE mark a part.

MarkApplies toWho can issueBuyer should hold
FDA 21 CFR / LFGBFood contact materialsResin producer, lab reportGrade statement, masterbatch declaration, finished-article migration test
EN71-1/2/3ToysAccredited labReport per decorated article and colourway
ASTM F963 / CPSIAUS toysAccredited labReport plus tracking label plan
REACH SVHCAll articlesSupplier declarationWritten SVHC statement per article
RoHSElectronics itemsSupplier declaration, lab testDeclaration for each electrical sub-part

The three gaps we see most

  • Certificates in another company's name. A certificate issued to a different moulding plant or a different grade cannot be transferred. Ask for the issuing body and the certificate holder to be named on the document.
  • Prop 65 confusion. California's Prop 65 warning is triggered by the retail channel and the listed substances, not by a failed test. Many compliant products still carry the warning label because the alternative is litigation risk.
  • Age grading treated as paperwork. Age grading drives the small-parts and torque testing regime. A toy graded 3+ that fails the small-parts cylinder is a design problem, not a certification problem, and no test house will pass it.

Related reading

Our platinum silicone component programme and food grade PP feeding set both ship with full declaration packs. The export regulations guide covers the shipping-side documents.

Related product categories

The materials and part types discussed above are grouped in our sourcing directory:

 
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