LFGB certification is the compliance gateway for food contact packaging sold in Germany, and it is increasingly a default requirement from European buyers. Named after the German Food and Feed Code (Lebensmittel- und Futtermittelgesetzbuch), LFGB goes beyond general EU rules in several important ways — most notably sensory testing and stricter market surveillance. This guide explains what LFGB certification covers, how it relates to EU regulations, the testing and documentation process, and the mistakes exporters make most often.
What Is LFGB and How Does It Relate to EU Rules?
Section 31 of LFGB is the core provision for food contact materials. It requires that materials must not release substances into food in quantities that endanger health, and must not cause an unacceptable change in the odor or taste of the food. That second requirement — sensory quality — is a distinctive German feature that goes beyond the chemical safety focus of most other regimes.
At the EU level, food contact materials are governed by the framework regulation (EC) No 1935/2004 and, for plastics, by Regulation (EU) No 10/2011. Germany applies these EU rules and layers its own national controls on top. In practice, German importers and retailers usually ask for both EU 10/2011 compliance and an LFGB test report. For a detailed comparison of the European and American frameworks, see our guide on EU 10/2011 vs FDA 21 CFR.
What Does LFGB Testing Cover?
LFGB testing focuses on four areas. First, sensory testing: odor and taste transfer tests, which are almost always required for the German market even though they are not mandatory under EU rules. Second, overall migration: the total amount of substances released when the material contacts food simulants under defined conditions. Third, specific migration: targeted analysis of heavy metals (lead, cadmium, mercury), primary aromatic amines, plasticizers, bisphenol A and other substances of concern. Fourth, a formulation review, checking that the resins, inks, adhesives and additives used are acceptable under German risk assessments.
A critical point for converters: LFGB compliance covers the entire packaging chain. Printing inks, lamination adhesives and even printed areas fall within the testing scope — you cannot focus only on the base film.
The LFGB Certification Process
LFGB is not a single certificate; it is a combination of laboratory testing and a declaration of conformity. The typical flow is: prepare samples that match your production formulation, and compile a full formulation dossier (component names and CAS numbers for resins, inks, adhesives and additives); send samples to an accredited laboratory — either a German-recognized lab or a CNAS-accredited lab with LFGB capability; and after receiving the test report, issue a declaration of conformity and keep the formulation and test records on file for inspection.
Standard testing takes roughly two to four weeks, and costs range from a few thousand to tens of thousands of RMB depending on the number of test items. Remember that the test report is tied to the formulation: change a raw material or adjust a process, and the compliance status must be re-evaluated.
Common Misconceptions
Mistake one: EU 10/2011 compliance is enough. Many German importers and retailers write LFGB test reports into their contracts; a generic EU declaration often will not satisfy them. Mistake two: the test report never expires. Any change in formulation, supplier or process can affect compliance, so you need a re-evaluation mechanism for formulation changes. Mistake three: only the finished bag is tested. German authorities trace intermediate materials, so films, inks and adhesives each need their own compliance documentation — start collecting it from your raw material suppliers.
Summary
LFGB certification is the entry ticket to the German market and a trust signal for premium brands across Europe. Three actions matter most: work with an accredited laboratory and test comprehensively, build a traceable formulation and documentation system, and push compliance requirements upstream into R&D and purchasing. To map out every certification you may need for food packaging exports, start with our US vs EU packaging requirements comparison and build your compliance checklist from there.
Preparing to export to Germany? Contact OMOpack for support with material selection and compliance documentation.
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