“FDA and LFGB certified” is a common supplier claim, but it does not tell a buyer which parts were assessed, for which market, or under what conditions of use. A reusable bottle may combine stainless steel, plastic, silicone, colorants, and decoration. Each material and the finished configuration need evidence relevant to the intended market.
This updated guide separates the US and EU food-contact frameworks, explains what an LFGB test report does and does not mean, and adds the EU plastic-material changes under Commission Regulation (EU) 2025/351 that buyers should now discuss with suppliers.
The short answer
There is no universal FDA or LFGB certificate that automatically approves every custom bottle. In the US, food-contact compliance depends on the regulatory status and conditions of use of substances that may migrate into food. In the EU, the general framework is Regulation (EC) No 1935/2004; plastic parts may also fall under Regulation (EU) No 10/2011, while other materials can be subject to national rules. A report only supports the product, materials, conditions, and test scope it identifies.
For an OEM quotation, ask for evidence tied to the exact bottle model, lid, seal, straw, color, and intended use—not just a certificate cover page.
FDA and LFGB are different kinds of terms.
What FDA compliance means in the United States
The US Food and Drug Administration regulates food-contact substances under the Federal Food, Drug, and Cosmetic Act and related rules. The FDA explains that the status of a food-contact article depends on each relevant substance and its intended use. A substance may be covered by a regulation, an effective Food Contact Substance Notification, a Threshold of Regulation exemption, a prior sanction, or another recognized basis.
That is why “FDA-approved bottle” is often too broad. Ask which components and substances are covered, whether the conditions of use match the intended beverage, and how the supplier traces any applicable notification to its manufacturer.
What “LFGB tested” usually means
LFGB is Germany’s Food, Commodities, and Feed Code. In drinkware trade, “LFGB tested” commonly refers to testing intended to support market or buyer requirements for Germany. It is not one universal government certificate issued for every bottle. The test report should identify the tested component, sample, method, conditions, and result.
Germany applies the EU food-contact framework alongside national provisions. The German Federal Institute for Risk Assessment (BfR) publishes material recommendations where relevant; BfR describes these recommendations as non-binding, science-based guidance. Treat an “LFGB” claim as a prompt to inspect the underlying evidence, not as a substitute for checking the destination market and product scope.
The EU framework buyers should map
Regulation (EC) No 1935/2004 sets the general EU framework for materials and articles intended to contact food. Food-contact materials must also be manufactured under Good Manufacturing Practice rules in Regulation (EC) No. 2023/2006. Plastic materials and articles have additional rules under Regulation (EU) No 10/2011. Where a material is not fully harmonized at the EU level, national provisions may also matter.
A stainless steel body, plastic lid, silicone gasket, straw, and printed decoration are not automatically covered by one identical test or declaration. The EU food-contact review is separate from general product safety and from packaging-waste obligations. See Funzlife’s EU PPWR checklist for custom drinkware packaging for the packaging rules.
What changed under EU Regulation 2025/351?
Commission Regulation (EU) 2025/351 amended the EU food-contact plastics rules and the GMP regulation. It has applied since 16 March 2025. The regulation also set transitional measures for certain plastic materials and articles made under the previous rules: qualifying articles first placed on the EU market before 16 September 2026 may continue to be placed on the market until stocks are exhausted. A separate provision requires certain intermediate products or substances first placed on the market after 16 December 2025, which meet the earlier rules but not the amendment, to carry a declaration limiting their use to final articles placed on the market before 16 September 2026. The transition depends on the specific article and supply-chain stage; do not assume an old report covers a new custom order.
For final plastic food-contact articles intended for repeated use, Article 14a adds instructions on slowing deterioration, observable changes that may signal deterioration, and warnings where specified damage or foreseeable misuse could increase migration or make the article unsuitable for further food contact. A separate provision covers consumer instructions for certain plastic articles at retail where listed substance restrictions apply.
For a bottle project, ask the importer or qualified food-contact specialist whether the relevant lid, straw, seal, or other plastic article falls within these provisions. Then confirm that the care instructions, warnings, and supporting documents match that component and the final product. The law does not make every stainless steel body a plastic article, and an EU rule update does not turn every supplier test into a legal certificate.
Illustrative buyer timeline. Applicability of transitional measures depends on the component, its supply-chain stage and when it was first placed on the EU market.
Review the complete bottle configuration.
Start with a component map. Record which parts contact the beverage, which contact the mouth, their materials and colors, and the intended conditions: beverage type, temperature, contact time, repeated-use pattern, and cleaning method. Include colorants, coatings, inks, or adhesives where relevant to the use or contact assessment.
| Component | What to identify before testing or document review |
|---|---|
| Inner steel and drinking rim | Grade, surface condition, and intended contact |
| Lid, spout, valve, and straw | Exact resin, color, supplier, and contact conditions |
| Gasket or seal | Material, formulation, supplier, and intended temperature |
| Coating and decoration | Process, material, location, and potential contact |
| Complete assembly | Model, revisions, intended use, and approved sample |
A report for a black standard lid may not automatically cover a new pigment, supplier, or redesigned valve.
What to request from a supplier before sampling
Put the evidence request in the RFQ so suppliers quote against the same scope. For plastic food-contact materials, the EU requires a Declaration of Compliance through relevant non-retail stages under the applicable specific rules; supporting documentation must be available to competent authorities. Buyers can request documents and scope information needed to evaluate their order, while confidential formulations may remain protected.
Ask for:
- A product specification and bill of materials covering the steel, lid, straw, seals, coatings, and decoration.
- The intended-use statement, including beverage, temperature, contact time, and repeated-use conditions.
- The applicable market basis and available declarations for each relevant component.
- Full laboratory reports, where tests have been performed, showing the sample identity, revision, materials, test method, conditions, date, and results.
- The current plastic-material documentation and an explanation of any reliance on transitional provisions under Regulation 2025/351.
- Written change-control terms for material, color, component supplier, process, or design changes after sample approval.
- The proposed care instructions and warnings for the final reusable configuration, where relevant.
For a wider quotation brief, use Funzlife’s custom stainless steel drinkware RFQ checklist. The quality-control guide explains how approved materials and samples can be connected to production checks.
Red flags to clarify before paying a deposit
Pause for clarification if one report is said to cover every model, the sample photo does not match the quoted lid, or the supplier cannot explain the tested conditions. Also distinguish a factory social audit or ISO management-system certificate from product-specific food-contact evidence. Neither an audit nor a general “food grade” statement proves that the finished bottle meets every target-market requirement.
Avoid asking only, “Do you have FDA and LFGB?” Instead, ask, “Please identify the food-contact components in our specified model, provide the available documents and reports for those exact materials and colors, state the intended-use conditions covered, and explain whether the EU 2025/351 changes affect the components in this order.”
Frequently asked questions
Does the FDA issue a certificate for every finished water bottle?
No universal FDA certificate automatically approves every finished reusable bottle. FDA’s food-contact framework evaluates relevant substances, regulatory bases, and conditions of use. Review the evidence for the actual components and intended use.
Is LFGB mandatory for every bottle sold in Europe?
“LFGB” is not a single EU-wide approval mark. EU food-contact rules, applicable national provisions, and buyer requirements depend on the materials and destination markets. Ask which legal basis and tests support the supplier’s claim.
Does Regulation 2025/351 apply to a stainless steel bottle?
It amends EU rules for plastic food-contact materials and articles and GMP. Its application to a bottle project depends on the plastic components and the product’s supply-chain history. It does not make the stainless steel body a plastic article.
Is a laboratory report enough for repeat orders?
Not by itself. Check whether the report matches the current model, material, color, supplier, intended use, and production revision. A change to a lid resin, pigment, seal, or supplier may require a documented scope review or additional evidence.
Prepare your custom drinkware RFQ
Funzlife helps brands, importers and promotional buyers review custom drinkware options, specifications, samples, packaging and quality-control requirements with appropriate manufacturing partners. We do not issue regulatory approvals or laboratory reports and do not replace the importer’s qualified compliance adviser. Send your target markets, bottle reference, quantity, lid configuration and available documents to discuss a practical next step.
Sources / Further Reading
- FDA: Determining the Regulatory Status of Components of a Food Contact Material
- European Commission: Food Contact Materials Legislation
- Regulation (EC) No 1935/2004 on food-contact materials
- Commission Regulation (EU) 2025/351, including amended rules and transitional measures
- Commission Regulation (EC) No 2023/2006 on Good Manufacturing Practice
- BfR Recommendations on Food Contact Materials
