In the last year we have witnessed, especially in Italy, an increase in the number of new, small and medium-sized enterprises that import pots, crockery and other materials in contact with food. So we thought it was time to publish an article on how to import this type of product.
In this week’s article, we explain everything you need to know to find the right manufacturer and why compliance with European regulations regarding food contact materials cannot be taken for granted when finding suppliers in China.
Manufacturing Cluster in China
Kitchen utensils do not belong to a homogeneous category of products, consequently their production is not concentrated in a particular city, region or province. That said, the places of interest for importers of cookware, tableware and other food contact materials are located in the following Chinese cities:
- Yangjiang, Guangdong: Stainless Steel Knives & Cookware
- Jiangmen, Guangdong: Stainless Steel Cookware
- Chaozhou, Guangdong: Stainless Steel Cookware
- Dongguan, Guangdong: Silicone, Rubber & Plastic Kitchen Utensils
- Jieyang, Guangdong: Cutlery
- Ningbo, Zhejiang: Stainless Steel Cookware
- Taizhou, Zhejiang: Silicone, Rubber & Plastic Kitchenware
- Yiwu, Zhejiang: Plastic Tools
- Yongkang, Zhejiang: Metal Cookware
- Xuzhou, Jiangsu: Glass objects
- Shijiazhuang, Hebei: Cast Iron Cookware
As you can see in the list above, most cookware and kitchenware manufacturers are located in the eastern provinces of Guangdong, Zhejiang, and Jiangsu. Still, it’s a brief overview. Do your research before hopping on your first flight to Hong Kong or Shanghai.
Product development
Most, if not all of our customers who import cookware and kitchen products, do so under their own brand. The most common alternative is to brand an existing factory design (ODM), rather than develop a new product from scratch. As indicated in the table above, the development of OEM products requires more resources than the branding of an existing product. Although a factory-designed product is not the same as a mass-produced one, it does save a lot of time by using existing product specifications.
| FACTORY | ODM | OEM | |
|---|---|---|---|
| Production time (in days) | 0 | 3 pm – 30 | 60 – 120 |
| Machining | Nobody | Reduced | Elevated |
| Minimum Order Quantity (pieces) | 500 – 1000 | 500 – 1000 | 1000 – 2000 |
Customizing a product also results in increased machining costs, the highest of which tends to be the cost of injection molding. In addition, the mold production time, especially for metal products, can easily be as high as two months. Unless you really need a custom-designed product, I would recommend ODM products.
Regulations
Food contact materials are regulated, to varying degrees, in most markets, particularly in the European Union and the United States. For most buyers and business owners in the industry, this may come as no surprise. However, there are a few things you need to know before making a deposit:
1. Compliance with European and American food contact materials should not be taken for granted. In reality, it is the exception, not the rule. For this reason, it is necessary to verify that the supplier demonstrates consistent proven compliance.
2. Wholesale products tend to be made for the Chinese market in the first place. As such, compliance with foreign regulations (e.g., 21 CFR), is not taken into account. In fact, China has its own set of regulations applicable to food contact materials. However, these regulations cannot be the same as those in Italy.
3. Manufacturers of kitchenware with a proven track record of consistent compliance cannot be the cheapest suppliers on the market. That said, there is nothing more expensive than a seizure.
4. The test report on a substance, for example, only proves that the sample of a specific batch has passed compliance tests. While this document is, in effect, an indication of “prior compliance,” it is not a compelling reason to neglect compliance testing on the batch(es) imported from your company. In fact, batch testing may even be required, if not by law, by your retailers.
Of course, different markets each have their own set of regulations, so you should first check what regulations apply to kitchen utensils and cookware in Italy before selecting suppliers. There are also different regulations that apply to certain types of cookware and food contact materials.
European Union
Member States of the European Union are free to establish their own regulations regarding contact with food, and some of these regulations specifically concern stainless steel products. As such, the landscape is somewhat fragmented. France, for example, requires stainless steel cookware to contain at least 13% chromium, while Italy has a list with different grades of stainless steel. There are also release limits regarding metals, alloys or the coating of cookware that can cause damage to health or the environment.
Other regulations apply specifically to plastic and ceramic materials in contact with food. In addition, there are also regulations and directives that apply to certain products such as coffee makers and catering equipment.
United States
Importers of stainless steel cookware in the United States must comply with FDA-administered regulations. There are also regulations generated by the American Iron and Steel Institute (AISI), more specifically AISI.304 and AISI.316. As is already the case in the European Union, the regulations are not only applicable to base materials, but also to substances present in coatings.
Cookware and kitchen utensils for commercial use (e.g., in restaurants) are treated differently than household products. There are similar differences for food contact materials intended for repeated use (e.g. a frying pan), compared to single-use products (e.g. food packaging).
Bisphenol A
Bisphenol A (BPA) is a chemical used in the industrial production processes of various plastics, especially transparent plastic packaging. To date, the European Union and the United States have banned the use of Bisphenol A in baby bottles, but this ban is not in force for use in pots, kitchen utensils and other materials in contact with food. In 2013, an FDA assessment deemed Bisphenol A safe, given its reduced level found in food contact materials:
The FDA’s current position, based on its most recent safety assessment, is that Bisphenol A is safe at current levels found in food. Based on the FDA’s ongoing safety reports on the scientific evidence, available information continues to support the safety of Bisphenol A for currently approved uses in food containers and packaging. Click here to learn more.
However, consumers in the aforementioned markets remain cautious about the content of Bisphenol A in plastic materials in contact with food which, in turn, has led manufacturers, at least those in Europe and the United States, to phase out this chemical.
What, in some ways, seems ironic, is that Chinese manufacturers are very interested in promoting their products as “free of Bisphenol A”, although they neglect the regulations in force in their reference markets and which regulate materials in contact with food. A similar trend can be found on Amazon.com, where sellers proudly advertise their products free of Bisphenol A. All of this is leading many importers to assume that their products are compliant if they are free of Bisphenol A, which, unlike many other substances, is not even required by law. Don’t get me wrong, though. Eliminating chemicals is never a bad thing, but it can’t just be the first thing you and your team should consider.
Additional regulations
As explained, importers must ensure compliance with all regulations regarding food contact materials. In addition, EMC regulations (e.g., FCC Part 15 and the European Union EMC Directive) and regulations regarding children’s products (e.g., CPSIA) may also apply depending on the type of product and its intended use.
The most important trade fairs in mainland China and Hong Kong
| FAIR | SEAT | PRODUCTS |
|---|---|---|
| Canton Fair Phase 1 | Guangzhou | Kitchen appliances and equipment |
| Canton Fair Phase 2 | Guangzhou | Kitchen utensils; stainless steel kitchen accessories, containers, dining tables, articles and decorations |
| HKTDC | Hong Kong | Cutlery, crockery, glassware, household appliances |
| Global Sources | Hong Kong | Kitchen, catering |
CDATF | Shanghai | Kitchen utensils, pots, cutlery, crockery, ceramic products, small appliances |
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