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Food-contact and potable-water certification

Which certifications a water or food-grade container needs, and what to request from a supplier.

Food-grade natural HDPE jerrycans in 5, 10 and 25 litre with tamper-evident caps
Food-grade HDPE, specified for contact rather than assumed.

A water or food-grade container is only as trustworthy as its paperwork. The material has to be right, and the evidence has to exist for the exact design you buy. This sets out what applies, what the documents prove, and what to ask for.

Quick answer: What certification does a drinking water container need?

A Declaration of Compliance with the destination market's food-contact rules, covering body and closures: FDA rules under 21 CFR in the US, Regulation (EC) 1935/2004 and, for plastics, 10/2011 in the EU. WRAS or NSF/ANSI 61 applies only where a buyer or a mains connection calls for it. For stainless, ask for an EN 10204 3.1 mill certificate.

Material first, because no certificate fixes the wrong one

Food contact starts, and often ends, with the material. AISI 304 stainless steel and food-grade HDPE are the safe bodies. Galvanized steel is not: zinc leaches from the coating, which is why the FDA Food Code bars it from acidic food and EU drinking-water rules accept it only with conditions. A painted or lined steel can is a fuel can, not a water can. Confirm the build is stainless or food-grade resin before you look at a single certificate, because the paperwork only certifies a material that was already correct.

Stainless has no liner in the wetted path, so there is nothing to chip, blister or wear through, and the thing being assessed is the alloy itself. A coated steel can is only food-safe while its coating is intact, which makes the claim conditional on a layer that a dropped filler nozzle can breach without anyone noticing.

Food-grade HDPE is approved as a resin with its additive package, so the grade and the masterbatch together carry the claim, not the polymer name. A can moulded in food-grade HDPE with a non-food-grade colourant is not a food-grade can. That shows up only if you ask for the declaration to cover the pigment as well as the resin.

What each market asks forThe US uses FDA food contact and NSF/ANSI 61. The EU uses framework regulation 1935/2004 and plastics 10/2011, moving to European Positive Lists. Great Britain uses Regulation 31 and WRAS. US EU UK Food contact Food contact: suitable for US✓ Food contact: suitable for EU✓ Food contact: suitable for UK✓ Drinking water Drinking water: suitable for US✓ Drinking water: suitable for EU✓ Drinking water: suitable for UK✓ Same file works Same file works: not suitable for US✕ Same file works: not suitable for EU✕ Same file works: not suitable for UK✕ UN mark needed UN mark needed: not suitable for US✕ UN mark needed: not suitable for EU✕ UN mark needed: not suitable for UK✕
Every market asks both questions and none accepts another market’s answer. Water is not a dangerous good, so no UN packaging mark applies to a potable container.

Why food contact and water contact are assessed differently

The two regimes look similar and test for different things, which is why a certificate for one does not answer the other. Food-contact assessment is built around foods and food simulants, tested for a stated contact time and temperature, in a matrix that is chemically busy to begin with.

Drinking-water assessment assumes the opposite conditions. Water sits in the container for long periods, it is nutritionally empty so anything that leaches has somewhere to go, and it is judged on taste, odour and whether the material supports microbial growth. A plastic that is entirely acceptable against a food simulant can fail on taste against water.

That difference is why the endpoints diverge. Food contact asks what migrates and in what quantity. Drinking water asks the same, then adds a standard taste and odour test against water and a microbial-growth test, which food-contact rules do not prescribe. Ask a supplier which of the two they hold, and for which market.

Which parts need their own declarationA food-contact claim covers every part the liquid meets, so the body, gasket, cap liner, spout and tap each need their own evidence. Touches liquid Own declaration Stainless body Stainless body: suitable for Touches liquid✓ Stainless body: suitable for Own declaration✓ Cap liner Cap liner: suitable for Touches liquid✓ Cap liner: suitable for Own declaration✓ Gasket Gasket: suitable for Touches liquid✓ Gasket: suitable for Own declaration✓ Tap body and seal Tap body and seal: suitable for Touches liquid✓ Tap body and seal: suitable for Own declaration✓ Outer coating Outer coating: not suitable for Touches liquid✕ Outer coating: not suitable for Own declaration✕
A tap alone can carry three materials from three suppliers. The commercial consequence is that closures belong in the specification rather than the consumable order: a replacement gasket bought on price can break a food-grade claim on a can that has not changed, and the break is invisible until somebody asks for the file.

The wetted path is more than the shell

A stainless body can be flawless and the can still fail a food-grade claim, because the gasket, the cap liner, the spout and the tap are plastic and elastomer, and they touch the liquid too. Food-contact compliance covers every part the water meets, not just the metal. When you ask for evidence, ask for it on the closures and seals as well as the body. It is where a food-grade claim most often quietly falls apart.

The cap liner sits against the liquid whenever the can is inverted or full. A gasket does the same permanently. A tap has a body, a seat and a seal, often in three different materials from three different suppliers. A spout adds a fourth. Each of those is a food-contact article in its own right and each needs its own declaration, so the answer to "is the can food-grade" is a set of documents.

Buy closures as part of the specification, not as a consumable. A replacement gasket sourced on price from a general supplier can break a food-grade claim on a can that has not changed, and the break is invisible until somebody asks for the file. Keep the closure and seal declarations with the product record rather than with the accessory order.

Which document answers which marketThe EU works from a framework regulation with a Union list. The US works through FDA regulations and notifications. Japan runs a positive-list system. EU US Japan Declaration of compliance Declaration of compliance: suitable for EU✓ Declaration of compliance: conditional for US~ Declaration of compliance: conditional for Japan~ Positive-list position Positive-list position: suitable for EU✓ Positive-list position: not suitable for US✕ Positive-list position: suitable for Japan✓ Substance notification Substance notification: not suitable for EU✕ Substance notification: suitable for US✓ Substance notification: not suitable for Japan✕ One file covers all One file covers all: not suitable for EU✕ One file covers all: not suitable for US✕ One file covers all: not suitable for Japan✕
Three different architectures, so a file built for one is not a file for another even where the material is identical. Which is why food-safe as a phrase means little and compliant with Regulation (EU) 10/2011 for aqueous foods at ambient temperature means something: it names the regulation, the food type and the condition.

The certifications that apply

  • Food-contact regulation. In the US, the FDA governs food-contact materials under 21 CFR. In the EU, framework Regulation (EC) 1935/2004 sits over plastics Regulation (EU) 10/2011, with national layers on top. The supplier issues a Declaration of Compliance (DoC) naming the regulation the material meets.
  • Potable-water approval. Drinking water adds a layer. WRAS in the UK tests that a material will not taint the water or feed microbial growth, and NSF/ANSI/CAN 61 in North America limits what leaches into it on health grounds. These sit separate from the food-contact DoC. Ask which your market expects.
  • Material certificate. For stainless, an EN 10204 3.1 mill certificate states the exact grade and composition of the steel that went into your cans, traceable to the melt. It is how you prove the body is genuinely 304 and not a cheaper substitute.

Markets do not agree, so name yours

Food-contact rules are national, not universal. The EU framework, the US FDA regime, the UK’s water approvals and Japan’s positive list for synthetic resins, which permits only listed substances in plastics, each ask for different evidence. A single “food-safe” claim means little across all of them at once. Tell your supplier the destination and the paperwork can follow the rules that apply there instead of a general impression of safety.

The regimes differ in structure. The EU works from a framework regulation with material-specific measures beneath it and, for plastics, a Union list of authorised substances. The United States works through FDA regulations plus food-contact notifications, so a substance can be cleared for a named use by a named notifier. Japan moved to a positive-list system for synthetic resins, where only listed substances may be used in plastic contact materials. Three different architectures, and a file built for one is not a file for another even where the underlying material is identical.

"Food-safe" as a marketing phrase is close to meaningless; "compliant with Regulation (EU) 10/2011 for aqueous foods at ambient temperature" is not. The second names the regulation, the food type and the condition, and those three together are what an importer's own compliance file needs. Ask for the claim in that shape and a supplier who cannot produce it will tell you so quickly.

The order the evidence has to be built inNo certificate rescues the wrong material, so the material is settled first and the documents are assembled against it rather than the other way round. Material
Right grade for the contents and duty
Wetted path
Body, liner, gasket, spout, tap
Test
Migration against the destination regime
Declare
A DoC naming the instrument
Buyers usually start at the last box and work backwards, which is why so many enquiries ask for a certificate before the grade has been chosen. The document is the output of the first three, not a substitute for them.

What to request, in one list

  • The Declaration of Compliance for your market’s food-contact regulation, covering the body and the closures.
  • A potable-water certificate (WRAS, NSF/ANSI 61 or the local equivalent) where your buyer or a connection to the mains calls for one. A portable can on its own falls outside both schemes.
  • The EN 10204 3.1 mill certificate for the stainless grade.
  • Confirmation that all of the above name the specific design and material you are buying.

If a supplier cannot produce these for the design in front of you, treat the food-grade claim as unproven.

Every part of the wetted path needs its own answerCertification follows the surfaces the liquid touches, and a can is an assembly of several materials from several suppliers. Needs its own DoC The container body The container body: suitable for Needs its own DoC✓ The interior coating or liner The interior coating or liner: suitable for Needs its own DoC✓ The closure gasket The closure gasket: suitable for Needs its own DoC✓ The pouring spout The pouring spout: suitable for Needs its own DoC✓ The dispensing tap The dispensing tap: suitable for Needs its own DoC✓ The outer paint The outer paint: not suitable for Needs its own DoC✕
One yes short of the whole column, and the exception proves the rule: the outside never touches the product. A declaration covering the body alone leaves four surfaces unevidenced.

How Fortitude21 handles it

Our stainless water and food-grade lines are AISI 304 across the wetted path, chosen so the metal itself is the barrier with no liner to fail. We supply the material and food-contact documentation against your order and destination market, and we will tell you plainly what we hold and what we do not before you commit. See the water and food-grade range.

Temperature and time move the answerMigration testing is done against defined conditions, so a declaration is valid for a contact regime rather than in the abstract. Covered by a standard DoC Ambient, short contact Ambient, short contact: suitable for Covered by a standard DoC✓ Ambient, months of storage Ambient, months of storage: conditional for Covered by a standard DoC~ Hot fill Hot fill: conditional for Covered by a standard DoC~ Repeated use over years Repeated use over years: conditional for Covered by a standard DoC~ Freeze and thaw cycling Freeze and thaw cycling: conditional for Covered by a standard DoC~
Four rows depend on the test conditions the declaration names. Tell us the contact time and the temperature at enquiry, because a declaration issued against the wrong regime is worse than none.

Match the can to the job

Food-grade means the material, evidenced.

Your use caseRecommended canWhy this one
Potable water, kept and refilled 20L Stainless Steel Water Can20L Stainless Steel Water Can AISI 304 across the wetted path.
Food and beverage at volume Food-Grade HDPE JerrycanFood-Grade HDPE Jerrycan Food-contact resin with documentation.
Food-grade, lying flat Horizontal Stainless Can — 5L / 10L / 20LHorizontal Stainless Can — 5L / 10L / 20L AISI 304, low-profile for a locker.
A static water supply point 20L Stainless Dispensing Can with Tap20L Stainless Dispensing Can with Tap Integrated tap, food-grade stainless.

Common questions

What certification does a drinking water container need?

It depends on the market. The US uses NSF/ANSI/CAN 61 for drinking water system components and FDA food-contact compliance for the material. The EU works through its food-contact materials regulation. The UK adds WRAS approval for products that connect to the public water supply, which a portable container does not. None of these is a UN dangerous-goods mark, which water does not need.

Is stainless steel food safe for water storage?

Austenitic stainless in 304 or 316 is food safe and does not need a liner or coating. It resists the chloride and biofilm problems that affect coated steel, and unlike HDPE it does not take up taint from previous contents. That is why it is the default for long-term potable storage.

Can I store drinking water in a fuel can?

No. A can that has held fuel retains hydrocarbon residue in its coating and seals that cannot be reliably removed, and a fuel can interior coating is not certified for food contact. Buy and mark water and fuel cans separately, and never swap them.

How much water should be stored per person?

The Sphere Handbook sets a minimum of 15 litres per person per day for drinking and domestic hygiene. It allows 7.5 litres for a short time in the acute phase of a drought, and treats 50 litres as the likely minimum in an urban middle-income setting. Survival intake alone is 2.5 to 3 litres per day.

References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

Last reviewed by David Guru, Co-Founder & Business Development Director.

Talk to us about your water programme

Tell us your market, where the water will be stored and your volumes. We come back with a specification sheet, the food-contact documents for that market and a quotation.

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