Selling Kettles in France: DGCCRF Metal Rules Checklist

A premium 1.7L 304 stainless steel cordless jug kettle with 2200W rapid boil — the typical export configuration shipped to the French market, and the SKU class that DGCCRF Arrêté du 13 janvier 1976 chemical composition testing applies to.

For a Chinese OEM shipping Stainless Steel Electric Kettles into France, the most common compliance gap is not the CE marking or the low-voltage directive (LVD) or the electromagnetic compatibility (EMC) test — it is food contact. The European framework Regulation (EC) 1935/2004 applies to all materials and articles intended to come into contact with food, and France has its own French-specific decrees that layer on top of the EU regulation. The DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) is the enforcement body. The kettle that sails through LVD and EMC testing can still fail at the French border if the food-contact documentation is incomplete.

This article walks through the metal-specific rules that apply to a Stainless Steel Electric Kettle sold on the French market, with the dossier-of-record checklist that the OEM manufacturer needs to provide to the European importer. The numbers and the document list are based on the export documentation we compile for the Goodfriends stainless steel kettle series shipped to EU customers, plus the published French guidance and the Council of Europe technical document that the DGCCRF applies.

1. What the DGCCRF Actually Does

The DGCCRF is the French administration in charge of consumer protection, market surveillance, and food safety enforcement (alongside ANSES, which handles the risk assessment side). For food-contact materials, the DGCCRF enforces the EU framework regulation (1935/2004) and publishes French-specific decrees that close the gaps where the EU has not harmonized. For stainless steel used in food contact, the relevant decree is the Arrêté du 13 janvier 1976, which sets chemical composition criteria for uncoated stainless steel and metal articles. The Arrêté does not, by itself, set migration limits — it specifies the alloy composition (Cr ≥ 13.0%, with additional alloy limits) and the testing responsibility flow between the steel mill and the finished-article manufacturer.

The DGCCRF also publishes Information Notes (Notes d'information) that are advisory rather than legally binding but are used in market surveillance. For kettles, Information Note 2004-64 covers metals and alloys, and Information Note 2012-93 covers other materials. Glass in kettle sight windows is also covered (Information Note 2004-64 explicitly lists glass and crystal). The compliance pathway for a Stainless Steel Kettle to France is therefore: Arrêté du 13 janvier 1976 for the stainless steel, EU 1935/2004 for the overall framework, the Council of Europe metals list for migration limits, and the relevant French Information Notes for documentation.

2. The Arrêté du 13 janvier 1976 — Stainless Steel Composition

The Arrêté du 13 janvier 1976 is the corner-stone of French food-contact metal compliance. For uncoated stainless steel, the decree specifies the following chemical composition rules:

304 stainless steel (also designated 1.4301 in the EN 10088-1:2014 European standard, or X5CrNi18-10 in the German DIN system) is the workhorse grade for kettle interiors. Its nominal composition is Cr 18%, Ni 8%, with the balance being iron and trace elements. The Cr 18% is well above the Arrêté's 13% minimum, and the other alloy elements are within the limits. 316 stainless steel (1.4401, X5CrNiMo17-12-2) is used for higher-corrosion applications and is also compliant. The two grades that are NOT compliant are 430 (Cr 16–18% but Ni-free, which is fine for the Arrêté but borderline for food contact in high-temperature applications) and 201 (Cr 16–18% but with high Mn content, used in Chinese commodity flatware — the Mn migration in hot-fill conditions is at the upper end of the SRL window and is rejected by some EU customer audits).

For a B2B buyer specifying a French-market kettle, the practical spec is 304 stainless steel (1.4301) with an EN 10204 3.1 mill certificate, the alloy breakdown certified within the Arrêté limits, and a separate declaration from the OEM manufacturer that the finished kettle meets the Arrêté's chemical composition requirement. The mill certificate is the steel mill's responsibility; the OEM manufacturer verifies and signs the declaration.

3. The Migration Limits — Council of Europe Metals List

The Arrêté sets composition, but not migration limits. Migration limits for food-contact metals in the EU are taken from the Council of Europe (CoE) technical document "Metals and Alloys Used in Food Contact Materials and Articles" — the practical reference is the CoE's Specific Release Limits (SRL) list, which is the table the DGCCRF applies in its market surveillance. The most relevant SRLs for a Stainless Steel Kettle are:

For repeated-use articles (a kettle is a repeated-use article under EU 1935/2004), the test protocol is: first migration test at the SRL, second migration test at 7× SRL, third migration test at the SRL. The first two tests can be at 7× SRL to demonstrate a stable surface; the third must be at SRL. The 304 stainless in a kettle passes the SRL test on the first migration under normal conditions, with the chromium and nickel migration well below the SRL after the first 2–3 brews that passivate the surface.

4. The Practical Test — FCM Sheet No. 1

The DGCCRF applies the Practical Guide for the compliance of metals and alloys used in food contact materials, published as FCM Sheet No. 1 (V02 - 01/04/2017). The test protocol for a Stainless Steel Kettle is:

• Food simulant selection. For a kettle that boils water, the simulants are distilled water (simulant A, for aqueous foods), 3% acetic acid (simulant B, for acidic foods), and 10% ethanol (simulant C, for alcoholic foods). The most severe test is simulant B at 100°C for 2 hours.
• First-use test. 2 hours at 100°C, single migration. All metals must be below SRL.
• Repeated-use test. 2 hours at 100°C, three migrations. First and second at 7× SRL; third at SRL.
• Hexavalent chromium. Non-detection with a detection threshold of 5 μg/dm², per the 13 February 1996 opinion of the CSHPF (Conseil Supérieur d'Hygiène Publique de France).

The accredited lab runs the test on the finished kettle (or, more commonly, on test coupons of the same alloy provided by the OEM manufacturer). The test report is the document that the European importer keeps in the dossier of record. EN ISO/IEC 17025 accreditation for the lab is required for the report to be accepted by the DGCCRF.

5. The Dossier of Record — What the OEM Must Provide

The dossier of record is the package of documents that the OEM (the Chinese manufacturer) sends to the French importer, and that the importer keeps available for the DGCCRF on request. Article 17 of EU 1935/2004 requires the dossier to be kept for 10 years after the last product was placed on the market. The dossier for an electric kettle made of stainless steel must contain:

For the Goodfriends 1.7L stainless steel cordless jug kettle with 2200W rapid boil, items 1–8 are the standard export package for the European market. The Chinese customs export declaration typically references the EU 1935/2004 compliance as the harmonized standard, and the importer-side fiches techniques (technical sheets) include the mill certificate and the migration test report in the dossier.

6. Plastic and Silicone Components — Don't Forget Them

A Stainless Steel Kettle is not 100% stainless. The handle, lid, base, water gauge, filter mesh, and any gaskets are typically plastic or silicone. Each of these is a separate food-contact material with its own compliance declaration. The relevant French decrees for the non-metal components are:

• Plastic components. EU Regulation 10/2011 (the EU Plastics Implementation Measure) is the primary regulation, with overall migration limit (OML) of 10 mg/dm² and specific migration limits for the monomers used. For the plastic handle and base, the OEM typically provides an overall migration test report.
• Silicone gaskets. The French Arrêté du 25 novembre 1992 covers silicone elastomers for food contact. The declaration includes the specific composition of the silicone rubber and the cure system.
• Rubber gaskets (if used). Arrêté du 9 novembre 1994 covers rubber for food contact, with a list of authorized polymer additives.

The OEM exporter who treats the stainless steel compliance as the only requirement will face a delay at the French border when the plastic components fail the overall migration test. The Goodfriends food-contact kettle for smart home automation configuration is one of the more complex products in the range because of the additional electronic components — every plastic enclosure that touches water or steam needs a separate EU 10/2011 declaration.

7. Lead Times and the Practical Timeline

For an OEM buyer placing a new SKU on the French market, the realistic timeline from drawing sign-off to a signed dossier of record is 6–10 weeks. The breakdown is:

The bottleneck is the migration test lab. Multi-product exporters queue the test slots in blocks of 4–6 weeks, and the lab cannot begin the test until the mill certificate is in hand and the finished kettle samples are received. The OEM exporter who plans ahead by 8 weeks from the PO date will hit the French market launch without slipping. The OEM exporter who treats the dossier as a "post-shipment paperwork" item will hold the shipment at customs for 6–10 weeks, plus pay a storage fee at the French port of entry.

8. The DIN-DGCCRF Gap and the Practical Workaround

One practical complication: the CoE metals list is not formally adopted into EU law (the EU has not harmonized metals and alloys under a regulation equivalent to the plastics 10/2011), so the SRL table is enforced by the DGCCRF as a market surveillance expectation rather than as a binding legal limit. In practice, DGCCRF market surveillance inspectors at the French port of entry will use the CoE list as the reference for sample retention and testing. The OEM exporter who hands over a dossier showing compliance with the CoE SRLs is essentially covered. The OEM exporter who references only the German BfR recommendations or the Italian ministerial decree (D.M. 21/03/1973) may face a longer clarification cycle with the DGCCRF.

The workaround is straightforward: cite both the Arrêté du 13 janvier 1976 (the French decree) and the CoE SRL list in the Declaration of Conformity. The importer keeps the same dossier under the EU 1935/2004 framework. This is the format the DGCCRF expects, and it is the format the French retailer expects when the brand manager reviews the compliance documentation.

9. Summary Checklist for the OEM Exporter

For the OEM exporter of a Stainless Steel Electric Kettle to France, the go/no-go checklist is:

• ✓ Stainless steel grade is 304 (1.4301) or 316 (1.4401), with EN 10204 3.1 mill certificate showing Cr ≥ 13.0% and Arrêté alloy limits.
• ✓ Finished kettle has a third-party migration test report per FCM Sheet No. 1 (V02 - 01/04/2017), from an EN ISO/IEC 17025-accredited lab.
• ✓ EU 1935/2004 Declaration of Conformity signed and referenced.
• ✓ EU 2023/2006 GMP declaration signed.
• ✓ Plastic, silicone, and coating components have separate declarations (EU 10/2011, Arrêté du 25 novembre 1992, Arrêté du 9 novembre 1994).
• ✓ French user manual is on file.
• ✓ Traceability and recall procedure documentation is on file.
• ✓ Dossier of record is stored for 10 years post-market by the importer.

When all eight items are in place, the kettle enters the French market with no DGCCRF risk. The total documentation cost is approximately 2,000–4,000 EUR per SKU (one-time, covers the test and dossier compilation), and the lead time is 6–10 weeks. For a B2B buyer evaluating a Stainless Steel Kettle for the French market, the right question for the OEM is not "is this CE marked" but "what is your Arrêté du 13 janvier 1976 dossier of record for this SKU."

FAQ

External References

The Arrêté du 13 janvier 1976 chemical composition requirements and the broader French food-contact regulatory framework are catalogued in the Contact Alimentaire reference publication, which is the official DGCCRF-authorized English-language regulatory compendium^[1]. The Arrêté's specific composition rules (Cr ≥ 13.0% and the alloy element limits) are documented in the same Contact Alimentaire reference^[2]. The overview of national EU food-contact legislation, including the French decree stack for stainless steel, aluminum, rubber, and silicone, is published in the ChemSafetyPRO regulatory reference^[3]. The SRL values for the 21 listed metals (Cr 0.25, Ni 0.14, Mn 1.8, Fe 40, Cu 4, Pb 0.01, Cd 0.005 mg/kg) and the 7×SRL repeated-use test protocol are taken from the Council of Europe metals and alloys reference document applied by the DGCCRF in market surveillance.

For B2B buyers sourcing 304 stainless steel 1.7L 2200W export kettles, requesting these documents at the RFQ stage compresses overall compliance clearance from 8–10 weeks to 4–6 weeks.