Water bottles, reusable cups and drinkware

• Regulation (EC) No 1935/2004 — food contact
• Regulation (EU) No 10/2011 for plastics
• Directive (EU) 2019/904 on single-use plastics
• Regulation (EU) 2023/988 — GPSR

Who has to appoint one

Manufacturers and sellers outside the Union placing drinkware on the EU market. Reusable products are food contact articles; single-use cups face the plastics Directive with marking requirements and, for some, outright bans.

Thresholds and exemptions

None. Single-use plastic cups require specific marking, and certain single-use items such as plastic straws and stirrers are banned entirely.

What must appear on the label

Manufacturer and responsible person details, batch identification, the food contact indication, and use restrictions such as maximum temperature, dishwasher suitability and unsuitability for carbonated or hot drinks. Single-use cups carry the mandatory marking on plastic content.

Marketplace fields

Marketplaces enforce the responsible person, and insulated bottles have been recalled for lead in the sealing plug at the base, which is the single most common failure in this category.

Documentation you must hold

Declaration of compliance for the food contact materials, migration test reports for every wetted component including lids, seals and the base plug, technical documentation and risk analysis, and evidence for any insulation performance claim.

Standards and testing

Overall and specific migration testing at the temperatures and contact times of use, lead and heavy metal release for metal components, thermal shock testing, and drop testing for the closure.

Language requirements

Use restrictions and cleaning instructions in the language of each member state of sale.

When it applies

Before the product is made available.

How long records are kept

Ten years.

What happens if you do not comply

Withdrawal and Safety Gate alerts, with lead release from bottle bases producing repeated recalls across the Union.

Who enforces it

Food safety authorities, market surveillance authorities and customs.

Where the boundary lies

Bamboo-melamine composite drinkware is prohibited for food contact regardless of its eco marketing. Insulated bottles hide a soldered plug that is rarely tested by the supplier and is exactly where authorities look.

Questions we are asked

Why do insulated bottles get recalled?

The sealing plug at the base is often soldered with lead-containing alloy, which releases above the limit when tested.

Is bamboo drinkware allowed?

Bamboo bound with melamine resin is not authorised for food contact in the Union and is removed from the market.