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Exporting Korean Silicone Suction Baby Dish Sets to France: EU and French Compliance Step by Step

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Silicone Suction Baby Feeding Dish Set hero

French distributors sourcing Korean silicone suction baby feeding dishes face two EU-wide deadlines that land within six weeks of each other in 2026: the REACH restriction on cyclosiloxanes D4, D5, and D6 takes effect June 6, and the EU ban on BPA in repeat-use silicone baby tableware applies July 20 — both require laboratory test data, not a marketing claim. On top of these EU deadlines, France adds a national silicone-specific law (the Arrêté du 25 novembre 1992) that neither FDA certification nor LFGB alone satisfies. This guide maps every compliance layer and shows the exact documentation path from a Korean factory to French customs clearance.

Why France Is a Different Compliance Market for Silicone Baby Tableware

The EU has no harmonised regulation for silicone food contact materials. The base framework — Regulation (EC) No 1935/2004 — requires all food contact materials to be inert: no constituent may transfer to food at harmful levels, alter food composition, or degrade taste or odour. Per the European Commission Food Safety Directorate, a Declaration of Compliance (DoC) is mandatory at every point in the supply chain, and quality assurance systems are required under the GMP Regulation (EC) No 2023/2006. However, 1935/2004 does not set silicone-specific technical requirements.

France fills that gap with the Arrêté du 25 novembre 1992, enforced by DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes). Per Légifrance, France's official legal database, this national order covers household silicone articles including baby feeding equipment, kitchen moulds, and tools. It requires:

  • Only authorised raw materials may be used in silicone manufacture
  • Materials must pass extraction testing against prescribed migration limits
  • Silicone must not alter the taste, odour, or organoleptic qualities of food
  • Materials must withstand authorised disinfection treatments

ANSES (France's food safety agency) adds the inertia principle: silicone must not transfer any constituent to food at levels that could harm consumers or change food composition. Per ANSES, this applies regardless of existing third-country certifications.

The practical result: LFGB test reports and BfR Recommendation XV compliance are necessary but not sufficient for the French market. As Lindemann Silikon notes, importers targeting France should request test reports explicitly referencing both BfR Rec XV and the French Arrêté 1992. If your current LFGB report does not cite the Arrêté, you need a supplementary lab report or written declaration before shipping to France.

The Full Compliance Stack for the French Market

Seven regulatory layers apply simultaneously to a silicone suction baby feeding dish set exported from Korea to France.

Layer 1 — EU Regulation (EC) No 1935/2004 and GMP (EC) No 2023/2006
The foundation framework for all EU food contact materials. Per the European Commission, a DoC is mandatory throughout the supply chain. Quality assurance and quality control systems must be documented under the GMP Regulation.

Layer 2 — BfR Recommendation XV (August 2024)
Per BfR, Germany's Federal Institute for Risk Assessment, Recommendation XV sets technical requirements for food contact silicone: authorised raw materials, cross-linking systems, additives, and migration testing protocols. An August 2024 update removed the previous 0.5% extractable threshold and added a new test method for heat-sensitive articles. EU member states — including France — widely treat BfR Rec XV as the current state of the art for silicone food contact compliance.

Layer 3 — Arrêté du 25 novembre 1992 (France)
The French national silicone law described above. Legally distinct from LFGB. Test reports must explicitly cite this regulation in addition to BfR Rec XV.

Layer 4 — EN 14350:2020+A1:2023 (Child Safety)
Per SGS, CEN published this amendment in August 2023. The standard covers drinking and eating equipment for children aged 0 to 48 months. Key points for silicone suction bowls and plates:

  • Migratable elements tested expanded from 8 to 19
  • Formaldehyde release, colour fastness, and primary aromatic amines are assessed
  • BPA testing was removed — it is now handled under food contact regulation
  • The standard now operates under EU GPSR (2023/988), in force from December 13, 2024

Layer 5 — REACH D4/D5/D6 Restriction (June 2026)
Per Intertek, on May 16, 2024, the European Commission adopted a REACH restriction on three cyclosiloxanes: D4 (octamethylcyclotetrasiloxane), D5 (decamethylcyclopentasiloxane), and D6 (dodecamethylcyclohexasiloxane). These are classified as very persistent and very bioaccumulative. After June 6, 2026, D4, D5, and D6 may not be present in products on the EU market at concentrations ≥ 0.1% by weight. Korean silicone manufacturers must verify their curing and compounding process does not leave residual cyclosiloxanes above this threshold in finished baby tableware.

Layer 6 — EU Regulation 2024/3190 — BPA Ban (July 2026)
Per EUR-Lex, this regulation entered into force January 20, 2025 and prohibits BPA, BPS, BPAF, and other bisphenols in food contact materials including silicone. For repeat-use silicone baby feeding dishes, the compliance deadline is July 20, 2026. A BPA-free marketing claim is not the same as documentary proof aligned with EU 2024/3190 — a test report or supplier declaration aligned with this specific regulation is required.

Layer 7 — EU GPSR 2023/988 — Importer Obligations (December 2024)
Per EUR-Lex, the General Product Safety Regulation applies from December 13, 2024. For French importers sourcing from Korea, direct legal obligations include:

  • Verify that the Korean manufacturer has fulfilled all safety requirements before placing the product on the French market
  • Ensure all product instructions and safety warnings are in French
  • Display the EU importer's name, registered trade name, postal address, and electronic address on the product or packaging
  • Conduct risk assessments throughout the product lifecycle

Two Deadlines That Cannot Move in 2026

Two 2026 Deadlines for Silicone Baby Tableware

Lab Testing Required — Self-Declaration Is Not Enough

June 6, 2026: REACH restriction on D4, D5, and D6 cyclosiloxanes takes effect. Silicone products with ≥0.1% by weight of these substances cannot enter the EU market. July 20, 2026: EU Regulation 2024/3190 BPA ban applies to repeat-use silicone baby feeding dishes. Both require accredited lab test results. A migration test from a lab in Korea takes 4–8 weeks; add shipping time. If your factory has not begun this testing, contact them now.

The REACH D4/D5/D6 restriction takes effect June 6, 2026. The BPA ban deadline for repeat-use silicone baby feeding dishes under EU 2024/3190 is July 20, 2026. Both require accredited laboratory test results — self-declaration is not accepted. Migration testing at an EU-recognised lab typically takes 4 to 8 weeks. Add 2 to 4 weeks for sample shipment from Korea. Importers whose suppliers have not yet generated these test reports should initiate the process immediately.

The Step-by-Step Path from Korean Factory to French Customs

Korean Factory to French Market: 5 Compliance Steps

  1. 1

    Gather Factory Test Reports and Traceability

    Request from your Korean supplier: BfR Rec XV test report explicitly citing the French Arrêté 1992, REACH D4/D5/D6 residual analysis, BPA/BPS-free declaration aligned with EU 2024/3190, raw material traceability records per ResAP(2004)5, and the baseline FDA 21 CFR 177.2600 test report.

  2. 2

    Commission EN 14350:2020+A1:2023 Testing

    Send product samples to a CEN-accredited laboratory — SGS, TÜV Rheinland, or Intertek. Tests cover 19 migratable elements, formaldehyde, colour fastness, and primary aromatic amines. Allow 4–8 weeks including shipping time from Korea.

  3. 3

    Issue the EU Declaration of Compliance (DoC)

    The EU importer — not the Korean manufacturer — bears primary responsibility. The DoC must cite EU Regulation (EC) No 1935/2004, list restricted substances and actual migration levels, specify food type and temperature conditions, and reference testing methods including BfR Rec XV and Arrêté 1992.

  4. 4

    Prepare French-Language Product Labelling

    Under GPSR (EU 2023/988), instructions and safety warnings must be in French. The EU importer's name, registered trade name, postal address, and email must appear on the product or packaging.

  5. 5

    Assemble Customs Documents and Ship

    For French customs under HS code 392490: commercial invoice, packing list, bill of lading, Certificate of Origin (for EU-Korea FTA tariff treatment), and the DoC. DGCCRF may request full test reports — have them ready in English with French summaries if possible.

Moving silicone suction baby feeding sets from a Korean manufacturer into France involves five ordered steps.

Step 1 — Gather factory test reports and raw material traceability. Request from your Korean supplier: a BfR Rec XV test report explicitly citing the French Arrêté 1992, a REACH D4/D5/D6 residual analysis, BPA/BPS-free documentary proof aligned with EU 2024/3190, full raw material traceability per Council of Europe ResAP(2004)5, and the baseline FDA 21 CFR 177.2600 report.

Step 2 — Commission EN 14350:2020+A1:2023 testing. Send samples to a CEN-accredited lab — SGS, TÜV Rheinland, or Intertek. Testing covers 19 migratable elements, formaldehyde release, colour fastness, and primary aromatic amines. This step is required because the product targets children aged 6 months and older.

Step 3 — Issue the EU Declaration of Compliance. Per ComplianceGate, EU importers — not Korean manufacturers — bear primary legal responsibility for issuing the DoC. Most Korean suppliers are not aware of EU DoC requirements. The document must include: issuing operator identity and address, product identity and declaration date, confirmation of compliance with EU Regulation (EC) No 1935/2004, information on restricted substances and actual migration levels tested, food type and temperature specifications, and testing methods referencing BfR Rec XV and the Arrêté 1992.

Step 4 — Prepare French-language product labelling. Under GPSR, instructions and safety warnings must be in French. The EU importer's contact details must appear on product or packaging. Verify that no unsubstantiated claims appear under French consumer law.

Step 5 — Assemble customs documents and ship. For French customs under HS code 392490: commercial invoice, packing list, bill of lading or airway bill, Certificate of Origin for EU-Korea FTA tariff treatment, and the DoC. DGCCRF market surveillance may request full test reports — have English originals and French summaries ready.

French Customs Documentation for HS Code 392490

French Customs Documentation Checklist

  • ✓ Commercial InvoiceShows unit value, quantity, and HS code 392490
  • ✓ Packing ListItemised contents of each carton
  • ✓ Bill of Lading or Airway BillSea or air freight transport document
  • ✓ Certificate of OriginFrom Korea Chamber of Commerce — required for EU-Korea FTA preferential tariff
  • ✓ EU Declaration of Compliance (DoC)Issued by the EU importer; cites EU 1935/2004, BfR Rec XV, and Arrêté 1992
  • ✓ EN 14350:2020+A1:2023 Test ReportFrom CEN-accredited lab — 19 migratable elements, formaldehyde, colour fastness
  • ✓ REACH D4/D5/D6 Analysis ReportConfirms cyclosiloxane levels below 0.1% by weight (required after June 6, 2026)
  • ✓ BPA/BPS-Free DeclarationDocumentary proof aligned with EU Regulation 2024/3190 (not just a marketing claim)
  • ✓ French-Language Product LabellingInstructions, safety warnings, and EU importer contact details in French — GPSR requirement

What the Declaration of Compliance Must Include

Per ComplianceGate, six elements are mandatory in every EU FCM Declaration of Compliance:

  1. Identity and address of the business operator issuing the DoC (the EU importer, not the Korean factory)
  2. Product identity and the date of the declaration
  3. Confirmation that the materials comply with EU Regulation (EC) No 1935/2004 and applicable specific regulations
  4. Information on restricted substances — including cyclosiloxane levels and BPA status — and actual migration results
  5. Food type, temperature range, and storage conditions under which compliance applies
  6. Testing methods used, with explicit reference to BfR Rec XV and the Arrêté du 25 novembre 1992 for the French market

The DoC must be available to DGCCRF market surveillance authorities and to all parties in the supply chain on request. Per the Council of Europe ResAP(2004)5, referenced by French authorities alongside the Arrêté 1992, full raw material traceability records should also be maintained by the silicone manufacturer.

How Starfield Commerce Supports French Importers

Starfield Commerce produces silicone suction baby feeding dish sets in food-grade 100% silicone — BPA, BPS, PVC, and lead free — with an integrated vacuum suction pad tested to 7 kg pull force. The set is microwave and dishwasher compatible and covers ages 6 months and above. The product holds FDA 21 CFR certification as a compliance baseline. Targeted certifications for the French and EU market — including BfR Rec XV with Arrêté 1992 reference and EN 14350:2020+A1:2023 — are available for discussion with buyers. ODM orders with brand colour options are available from MOQ 1,000 units, with monthly capacity of 50,000 units.

Last updated: 2026-06. This guide is for general informational purposes. EU and French import regulations can change. Confirm current requirements with DGCCRF, ANSES, and a licensed European customs specialist before you ship.

Frequently Asked Questions

Is the French Arrêté du 25 novembre 1992 the same as LFGB or BfR Recommendation XV, or do French importers need separate testing?
They are legally separate requirements. Per Lindemann Silikon, LFGB test reports and BfR Rec XV compliance are not the same as compliance with the French Arrêté 1992. The Arrêté is a national French law enforced by DGCCRF, with its own authorised substance list, extraction test protocols, and organoleptic requirements. Importers targeting France should request test reports that explicitly cite both BfR Rec XV and the French Arrêté 1992. If a current LFGB report does not reference the Arrêté, a supplementary lab report or declaration is needed before the products enter France.
As an EU importer sourcing from Korea, am I responsible for issuing the Declaration of Compliance even if the Korean factory already has FDA and LFGB certificates?
Yes. Per ComplianceGate, EU importers — not the Korean manufacturer — bear primary legal responsibility for issuing the EU Declaration of Compliance for food contact materials. Most non-EU suppliers are not familiar with EU DoC requirements. The DoC must be issued by the EU business operator placing the product on the market, and it must be available to DGCCRF market surveillance authorities on request. Korean factory certificates are input evidence for your DoC, not a substitute for it.
What is the exact deadline for the BPA ban transition period for silicone baby tableware sold in France?
Per EUR-Lex, Commission Regulation (EU) 2024/3190 entered into force January 20, 2025. For repeat-use silicone food contact articles — which includes baby suction dishes — the compliance deadline is July 20, 2026. A potential extension to January 20, 2028 exists only for professional food production equipment, not for consumer baby feeding products. Documentary proof (test report or supplier declaration aligned with EU 2024/3190) is required — a BPA-free label or marketing claim does not satisfy this regulation.
Does GPSR (EU 2023/988) apply to silicone suction baby dishes, and what must be labelled in French?
Yes. Per EUR-Lex, the General Product Safety Regulation (EU 2023/988) applies from December 13, 2024, and it covers baby feeding equipment including silicone suction bowls and plates. Under GPSR, EU importers who source from Korea must: verify the manufacturer has met all safety requirements, ensure instructions and safety information are in French (the language of the member state), and display the importer's name, trade name, postal address, and email on the product or packaging. The regulation also requires risk assessments throughout the product lifecycle.
How does the REACH restriction on D4, D5, and D6 cyclosiloxanes affect Korean silicone baby suction bowl imports to France?
Per Intertek, the EU-wide REACH restriction on D4 (octamethylcyclotetrasiloxane), D5 (decamethylcyclopentasiloxane), and D6 (dodecamethylcyclohexasiloxane) takes effect on June 6, 2026. After that date, these substances must not be present in products placed on the EU market at concentrations ≥ 0.1% by weight. This applies to finished baby tableware, not just raw silicone. Korean manufacturers must verify through accredited lab testing — not factory declaration alone — that their curing and compounding process does not leave residual D4/D5/D6 above the threshold. Importers sourcing from factories that have not yet run this analysis should request it now.

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