Stainless steel bottle testing for safety & compliance. How is it done?

Stainless steel bottle testing is something importers need to get right as they’re classed as a food contact material product (FCM). They’re a hot product and something we’re asked about quite regularly.

In this post, we’ll explain the kinds of compliance testing required to get stainless steel products onto the market whilst assuring user safety.

Why are reusable bottles so popular?

The popularity of reusable bottles is rocketing as consumers are starting to recognise how harmful single-use plastic bottles are for the environment.

In a report referenced by the Guardian newspaper, it was stated that:

“Plastic is among the most significant and rapidly growing sources of industrial greenhouse gas emissions. Emissions from plastic emerge not only from the production and manufacture of plastic itself, but from every stage in the plastic lifecycle – from the extraction and transport of the fossil fuels that are the primary feedstocks for plastic, to refining and manufacturing, to waste management, to the plastic that enters the environment.”

According to the University of Colorado, Boulder:

Plastic contains chemicals that are known endocrine disruptors and pose a threat to human health. Human exposure to plastics with these chemicals can cause hormonal imbalances, reproductive problems, and even cancer.

As well as increased awareness by environmental and health-conscious consumers, governments around the world have been stepping up with legislation and infrastructure to encourage a reduction in plastic waste. 

Let’s take the city of Paris’ L’eau de Paris initiative and public company (website in French) as an example of this. They provide almost half a million cubic metres of potable water per day to Parisians through a network of hundreds of free water fountains dotted around the city and its suburbs, some even offering sparkling water for those who prefer it! Therefore, there’s now little reason to purchase bottled water in Paris!

It’s clear then that stainless steel bottles are a hot product for today’s consumers and many brands are choosing to manufacture them, perhaps simply adding their brand to an existing design in many cases.

Here’s a list of stainless steel bottle benefits

• Consumers save money over buying expensive bottled water
• Fewer fossil fuels are probably used to produce them
• Energy usage is reduced (as plastic production is energy-hungry)
• Stainless steel cleans easily and therefore protects the user from bacteria build-up that can occur in bottles made from other materials
• They’re can be recycled (not all plastics are easily recyclable)
• Plastics can contain BPAs and other harmful substances, whereas stainless steel is non-toxic. It is relatively safe for human use, so much so that it’s used to produce surgical instruments
• The average stainless bottle is far more durable than a plastic bottle
• They can contain both hot and cold drinks (and vacuum stainless bottles will keep drinks cold or hot for many hours), but many plastic bottles aren’t suitable for hot liquids

What regulations do we follow for testing compliance of reusable bottles like this in Asia?

There are many reasons to manufacture stainless steel bottles in Asia, but, as a food contact material product, the compliance regulations you need to test for are quite rigorous.

An example of typical stainless steel bottle compliance testing requirements could be as follows for a bottle that is set to be sold in the EU and the USA:

1. Food Contact Materials – Regulation (EC) 1935/2004 – Requires that all FCMs that will be in contact with food materials like reusable stainless steel bottles that will be imported and sold in the EU) intended to come into contact with food to comply with it. For example, article 3 makes it clear that the FCM product must not release any substances into food at levels that could endanger human health or change how the food looks, smells, or tastes by tainting it. They should also be manufactured following acceptable GMPs (good manufacturing practices).
2. Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food*- Outlines the safety requirements for plastics (such as FCM products) that will be in contact with food and are intended to be imported into and sold in the EU. The regulation clarifies substances like PFAs (BADGE), Nitrosamines, and Polyvinyl chloride that are restricted and must not migrate into food at a harmful level.
   
   *Plastic testing would be done because a stainless steel bottle may have some plastic components that will be in contact with the contents, such as a lid.
3. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) – Regulation (EC) 1907/2006 – REACH is in place to protect human life and the environment by controlling which chemicals are in products being imported into the EU. It outlines a list of Substances of Very High Concern (SVHC) that must be avoided and enables the chemical composition of finished products to be tested and assessed for compliance with safe levels.
4. FDA CFR 21 (Food contact materials) – Food contact material products that are intended to be sold on the US market need to comply with the various provisions outlined here that apply to their type. For instance, CFR 21 174 – General provisions applicable to indirect food additives is perhaps most relevant to a stainless steel bottle.

Here’s an example testing plan for bottles (it includes PP plastic, silicone, and stainless steel) that will illustrate what’s tested:

“We’ve heard that lab testing for FCM compliance can be quite expensive. Is this normal?”

Yes, food contact material testing always costs more than a few hundred dollars (that’s probably about average for standard consumer products) as this is a particularly sensitive product type.

Some companies reduce their testing costs by designing the product to use materials that come from sources that are already certified as safe for food contact (verifying the certificates your supplier gives you is still a must though). 

However, if there are no existing certified materials on the market right now, in principle they all have to be fully tested.

REACH testing can be particularly expensive. If some of the SVHC listed in the REACH directive are not in your product, then these may be omitted from lab testing and the costs will be reduced accordingly.

However, if you require a REACH certification then ALL the restricted substances must be tested for.

If the testing is a strain on your budget, how to proceed becomes a business decision. Maybe you only do some of the tests (on only some of the materials) on the first production batch. Then some other tests on the next batch. And so on. That’s what some importers on a tight budget do. But, of course, you are still taking some compliance risks if you do that.

How does the testing process work at Sofeast, once production has started?

We usually advise importers in this position to combine product inspections and lab testing.

Samples will be taken by a quality inspector during production and these will be sent to the lab for compliance testing before the products are even finished by your supplier.

Let’s break down the process:

• Product inspections

Usually, clients will book the following:

• Inspection during production 
• Final random inspection 
• Packing & loading supervision (especially with a new supplier or important shipment) 

These inspections are usually 299USD per man-day in the key manufacturing cities in China, Vietnam, or India.

• Lab compliance testing

For lab testing, our inspector picks out some samples during the product inspection and sends them to your nominated lab (we can also help to liaise with some ISO 17025 certified labs if you need a suitable lab to be sourced, costs apply).

If you are unsure which regulations your product needs to comply with and need help to create a testing plan (similar to the example you saw earlier), we can help you if we are working on this as an integrated program.

• Certificate verification

Your supplier may provide you with certain certificates that they claim demonstrate the materials they’ve used in production are safe and compliant or that the product is already compliant with EC/FDA standards, for example. But it’s not safe to take their word for it. Therefore conducting your own certificate verification assures that your compliance isn’t being compromised early on.

We can check the certificates for you within around 48 hours and the cost is 99USD if fewer than 3 certificates to verify, and 30USD per certificate for each additional one.

It’s always best to send us a copy of the certificates so we can check if they can be verified.

• Booking the quality inspections and lab tests

To book, customers will need to send us the quantity of each item being checked and the supplier’s contact details, including their email address and mobile number, and register with us. 

Do this by creating your company’s account on our IT platform.

Conclusion

Reusable bottles are great for your health and the environment, that’s why they’re seen everywhere these days from the gym to the classroom. Few environmentally-conscious consumers want to see even more single-use plastic bottles being used, so importers are manufacturing stainless steel bottles to cater for their wishes in greater numbers.

Stainless steel bottle testing is fairly comprehensive as these bottles are classed as FCM (food contact materials) and have a direct impact on human health and safety.

While the testing can be quite expensive, there are ways to reduce costs, such as only testing for certain chemicals if you know that others are definitely not present.

Are you producing these bottles? What challenges have you faced and do you have any questions about testing for compliance?

P.S. If you’re stuck and need help to work out which regulations your product needs to comply with and/or to create an appropriate testing plan, we can help you with this solution: Compliance Testing Consulting.