What do LFGB §30 and §31 require for plates and coatings sold in Germany?

What does LFGB mean?

LFGB is the short name for the Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch. In English that is roughly the Food, Consumer Goods and Feed Code. It is the main German federal law for food, and it also covers “Bedarfsgegenstände”, the legal term for things that touch food: plates, bowls, cutlery, packaging, pans.

When a German buyer says “send me your LFGB report”, they mean a laboratory test showing the product meets the food-contact sections of this law. In practice that means §30 and §31.

What does LFGB §30 actually say?

§30 is headed “Verbote zum Schutz der Gesundheit”, prohibitions to protect health. It contains three bans. You may not make or treat food-contact articles for others in a way that lets their material harm health in normal or foreseeable use. You may not place such articles on the market. And you may not use them to make or handle food in a way that makes the food harmful to eat.

The test in §30 is the material itself. Toxic substances or contaminants in the plate are the problem it targets, whatever the plate is made of.

What does LFGB §31 add?

§31 is headed “Übergang von Stoffen auf Lebensmittel”, transfer of substances to food. Its first paragraph forbids using or selling food-contact materials that do not meet Article 3(1) of Regulation (EC) No 1935/2004. That EU article says materials must be made under good manufacturing practice so that, in normal or foreseeable use, they do not transfer their constituents to food in quantities that could endanger health, bring an unacceptable change in the food’s composition, or spoil its taste and smell.

So §31 is where taste and odour come in. A plate can be non-toxic and still fail if it makes a curry smell of the plate. The rest of §31 lets the ministry set substance limits by regulation, and bans selling food that was made using a non-compliant article.

Does LFGB apply to coatings on plates and cookware?

Yes. Most searches for “LFGB coating” come from non-stick pans and coated paper, and the answer is the same for both. §30 and §31 look at the finished article as it touches food. If there is a coating, a lining or a binder, that layer is what the food meets, so that layer is what the migration test has to cover.

This is where coated disposables get harder to document. A paper plate with a plastic film or a grease barrier needs the barrier identified and tested, and plastic layers also fall under the EU plastics rules. Our plates have no such layer. They are pressed from fallen areca sheaths with heat and pressure, with no glue, no coating and no chemicals, so the lab is testing the leaf and nothing else.

If a supplier tells you their coated product is “LFGB approved”, ask which layer was tested and in which simulant. A report that only covers the base material says nothing about the coating.

What should an LFGB test report contain?

The law itself does not name test methods, so the report is where the detail lives. When I read a competitor’s report, or a buyer reads ours, these are the things worth checking:

• The laboratory’s name and its ISO/IEC 17025 accreditation. For German labs the accreditation body is DAkkS.
• A product description that matches what you are buying: shape, size and material, not just “palm leaf plate”.
• The simulants used, with contact time and temperature. Hot or fatty food needs harder conditions than dry snacks.
• Measured values next to the limits, not only the word “pass”.
• A sensory result for taste and odour.
• The test date and a signature.

There is no legal expiry date on a report. Many German buyers still ask for one under two years old, and I think that is reasonable. If a supplier cannot send a report within a day or two of being asked, I would treat that as a warning.

Is an EU declaration under 1935/2004 enough for Germany?

For plastics and a few other materials, EU law has specific measures that require a written declaration of compliance. Article 16 of 1935/2004 only makes that declaration mandatory where such a specific measure exists. Plain plant fibre like areca leaf has no EU measure of its own, so the general Article 3 rule applies, and German law enforces it through §31.

That is why German buyers ask for a lab report rather than a declaration alone. The declaration states your position. The report is the evidence behind it. We supply the report, and buyers who want a declaration in their own format can send us their template. Our glossary entry on EU 1935/2004 covers the EU side in more detail.

Who is responsible for LFGB compliance, the maker or the importer?

Whoever places the plate on the German market. For goods made in India, that is normally the importer. The food inspectors in each German state (Lebensmittelüberwachung) deal with the company in Germany, not with us in Karnataka.

Our job is to give you a report you can stand behind and to keep batches traceable to it. Your job is to check the report matches what you bought and to keep it on file. If you also have to register packaging in Germany, our Germany import guide covers the LUCID register and the customs side.