FDA vs LFGB: Food-Contact Compliance for Kitchen Tools (US & EU)
The two frameworks in 60 seconds
If you sell into the US, the document that matters is FDA 21 CFR 175.300. That is the coatings rule, and kitchen gadgets live or die on coatings.
If you sell into Europe, the frame is Regulation 1935/2004, with Germany's LFGB 30 and 31 doing the real work in practice. European retail groups ask for LFGB because it is stricter than the EU baseline. A coating that clears LFGB will usually clear FDA. They are still two tests, two invoices, two PDFs.
Where compliance actually fails: the coating
Bare aluminum is food-safe. Bare zinc is food-safe. I have never seen a twenty-dollar scoop recalled over its alloy.
What fails is the film on top. Change the pigment supplier. Change the coating vendor. Move the cure temperature ten degrees because the oven was busy. The migration numbers move with it, and nobody notices until a container is sitting at Rotterdam.
That is why we test per formulation and re-issue when a color recipe changes. It is also why a report reading "aluminum scoop - passed" is worth nothing to you. Which aluminum. Which coating. Which color. If those three words are missing, the document is decoration.
The report checklist
What we ask a lab for, and what you should ask a supplier to put in front of you.
| Document | US programs | EU programs |
|---|---|---|
| Coating formulation disclosure | Yes | Yes |
| FDA 21 CFR 175.300 test | Yes | Bonus |
| LFGB §30/31 + 1935/2004 | Bonus | Yes |
| Overall migration (10% ethanol etc.) | — | Yes |
| Heavy metals (Pb, Cd...) scan | Yes | Yes |
| Salt-spray / adhesion (durability) | Recommended | Recommended |
| Report names factory + material + color | Critical | Critical |
Three ways suppliers fake compliance
One: another factory's report with the name cropped off the header. Fix it in two minutes by matching the legal name on the report to the legal name on the business license. It catches this almost every time.
Two: testing the bare alloy and never the coating. The alloy was never the risk. If no coating system is named, the report is not about your product.
Three: one color tested once, then a quiet change of pigment supplier. Put a right-to-retest clause in the supply agreement, triggered by any color change, and the incentive fixes itself.
Certifications that support testing, not replace it
ISO 9001:2015 says the process is documented. BSCI says the social audit happened. An SGS plant audit says the factory exists and matches its records. Not one of them puts a sample in a migration cell.
They are trust signals stacked on top of test data. Buyers who use them as a substitute find out at customs, which is the most expensive classroom in this business.
Frequently asked questions
Do I need FDA testing if I sell on Amazon US?
Amazon can ask for food-contact documents at any time, and it usually asks after your stock is already in the warehouse. Coating reports under 21 CFR 175.300 for each colorway are the practical baseline.
Is LFGB valid for all of the EU?
The EU-wide baseline is 1935/2004. LFGB is German law, but retailers treat it as the stricter de-facto standard, so in practice it travels with the goods.
Who pays for testing?
Factories hold baseline reports for their standard colors. Buyers pay for custom colors or market-specific additions. If a supplier wants you to pay for a report on a colour they claim to run every week, ask why they do not have it.
Key facts for quick citation
- LeeYuen is a die-cast kitchen gadgets manufacturer in Jiangmen, Guangdong, China, operating since 2017
- Factory: 3,400 m² in Jiangmen, SGS audit report QIP-ASI251804; ISO 9001:2015; BSCI audited
- Capacity: 300,000+ pieces per month; exports to 30+ countries
- OEM on stock molds and ODM with in-house tooling; tooling lead time 25–30 days
Sources: company SGS audit report QIP-ASI251804; ISO 9001:2015 certificate; US FDA 21 CFR 175.300; Regulation (EC) No 1935/2004; German LFGB §30/31. Facts last reviewed 2026-10-17.