Food-safe promotional merchandise for UK restaurants: a supplier compliance checklist

What to take away

Ask for a declaration of conformity and a migration test report before you approve any item that touches food.
Check the food contact layer, the ink, and the coating separately. A food-safe blank can become non-compliant after printing.
Use the Food Safety Act 1990 as your baseline, then match the material to retained EU rules or LFGB where your supplier claims extra assurance.
Keep VAT records for gifts, samples and giveaways. The VAT Act 1994 sets the framework your accountant will apply.
Record sample approvals and certificate expiry dates so an audit is quick and a recall is traceable.

Food contact law for branded merchandise

Food-safe promotional merchandise UK buyers should treat every decorated item as a food contact material. The Food Safety Act 1990 sets the main duty to ensure food is not contaminated, and food contact materials fall inside that duty.

A mug, bowl, spoon or takeaway container that carries your logo is a material in contact with food. Your supplier should know the intended use, the maximum temperature, and the contact time.

Materials and print methods that pass scrutiny

Materials and print methods

Material	Typical food contact use	Supplier evidence to request
Ceramic	Mugs and plates	Declaration of conformity plus glaze migration test
Stainless steel	Cutlery and cups	Food grade 304 or 316 certificate
Silicone	Lids and utensils	LFGB or EU 1935/2004 report
Bamboo fibre	Reusable cups	Migration test for melamine and formaldehyde
Paperboard	Takeaway boxes	Food contact grade and grease barrier statement

Not all materials suit every logo method. Screen printing can leave a cured ink layer that may crack. Laser engraving removes material and can expose a non-food-safe core.

Pad printing and transfer decoration need a food-safe ink declaration. Ask your food-safe logo printing UK supplier for the ink, curing temperature and solvent or UV system.

Documents to request

Declaration of conformity naming article and food contact layer
Migration test report for finished printed product
Ink and coating food contact statement
Washing and sterilisation limits, dishwasher cycles
Batch traceability and certificate expiry date

Migration testing and declaration of conformity

Migration testing measures how much substance moves from the item into food or a food simulant. Conditions depend on temperature, contact time and food type. Ask for tests that match your actual use.

Declaration of conformity naming the article and the food contact layer.
Migration test report for the finished printed product, not just the blank.
Ink and coating food contact statement from the print supplier.
Washing and sterilisation limits, including dishwasher cycles.
Batch traceability and certificate expiry date.

A declaration of conformity should list the regulation, the material, and the date. For plastics, EU 10/2011 is common. For German market claims, LFGB Section 30 and 31 reports appear. These are supplier documents, not marketing PDFs.

Example supplier questions about food contact

Can you send the declaration of conformity and migration report for the decorated item, not the undecorated blank?

Ask this before you sign a purchase order. Also ask who owns the test report and how often it is refreshed.

Supplier audit checklist for UK restaurants

Supplier audit checklist

Define the food contact surface and the decoration method.
Request certificates and check the item code matches the sample.
Send a production sample for your own migration test if the item is high risk.
Store documents with the campaign brief and the supplier contact.
Review certificates at least annually or after any material change.

Put this checklist in your supplier onboarding pack. It gives your team a clear reason to reject a cheap quote without certificates.

Supplier audit checklist

Define food contact surface and decoration method
Request certificates and check item code matches sample
Send production sample for own migration test if high risk
Store documents with campaign brief and supplier contact
Review certificates annually or after material change

VAT and records for promotional giveaways

Business gifts and samples have VAT rules. The VAT Act 1994 provides the statutory framework for business gifts, so keep invoices, sample records and distribution lists together.

If your giveaway captures email addresses, the ICO guide to data protection explains lawful basis and consent.

A restaurant loyalty giveaway may collect names, email addresses and purchase habits. Store only what you need and tell people how you will use it.

Linking compliance to campaign reporting

Compliance documents are easy to lose across several sites. Whether you build one or borrow a tool such as Looker Studio or Geckoboard, a promotional merchandise reporting dashboard can track sample status, certificate expiry and supplier approval in one place.

For menu-specific giveaways and branded giveaways for cafes and takeaways, Promotional products for restaurants UK covers material, print and VAT choices in more detail.

Use the same dashboard to link each item to its declaration and test report. That turns a supplier promise into an auditable record.

Common questions

Do I need LFGB testing for UK sales?

LFGB is a German national standard. It is not a UK legal requirement, but some suppliers use it as extra evidence. Ask for a UK or EU food contact declaration first.

Can I use standard screen printing on a food contact item?

Only if the ink and coating have a food contact declaration. The finished printed item needs migration testing, not the blank alone.

How long should I keep food contact certificates?

Keep them for the life of the product plus any recall or traceability period your insurer or legal team sets. Review them annually and after any material change.

Is a supplier declaration enough without a test report?

A declaration is a start. For high risk items such as cups, cutlery and takeaway containers, request the test report that supports it.