Who carries which obligation
Compliance for wooden kitchenware divides cleanly into three roles. You, as the buyer and usually the importer of record, carry the declarations and the market-facing claims. The partner workshop carries the material facts: which species, which finish system, which adhesive in a bamboo panel. The desk carries the flow of information between them, written onto spec sheets and program documents so that nothing rests on a verbal assurance. One rule governs this page and everything the desk says: we describe what rules cover and when they apply, and we never claim that SylvanSet or a workshop holds a certificate. Where a report exists, it is identified and confirmed per program; where it does not, we say so.
Lacey Act: the declaration at entry
The Lacey Act requires importers of wood products formally entered into the United States to file a declaration at entry, submitted electronically through CBP's ABI system, stating the plant species name, the country of harvest and the quantity. Wooden kitchenware falls under HTSUS Chapter 44, and bamboo products are included as plant products even though bamboo is technically a grass. The declaration is handled by the importer of record, usually you or your customs broker; what the desk supplies is the input data, the species name, the origin basis and the quantities, taken from the program's spec sheet so the declaration matches the cartons. Because we state species and origin basis generally rather than claiming a specific mill's log origin, the spec sheet is written to give your broker exactly what the declaration needs and no invented detail. The mechanics are walked through in our note on the Lacey Act declaration for wooden utensils.
FDA food-contact expectations
For food contact, FDA's expectation starts with the material itself: wood food-contact articles must be clean. The finishes applied to cooking surfaces fall under FDA's framework for food-contact substances, the rules in the 21 CFR 174-186 range. In practice, the programs we coordinate use food-contact oils, commonly mineral oil, sometimes blended with beeswax or a walnut-oil blend, precisely because they are the finish category this framework contemplates for wood. The buyer's task is to confirm the finish system's documentation: which finish, from which supplier, with what supporting papers. The desk puts the finish system on the spec sheet by name so that documentation can be requested and checked rather than assumed. What the framework does not do is certify a product, which is why our copy guidance below matters.
LFGB for EU buyers
Buyers shipping into Germany and often the wider EU ask about LFGB, the stricter German food-contact framework. Where a workshop holds test reports relevant to your finish system, those reports are identified and confirmed per program in writing; where none exist for the exact combination you specify, the honest answer is that testing is your decision to commission, and the desk coordinates samples for it. We do not generalize one workshop's report across another workshop's product. The two frameworks are compared in our note on LFGB versus FDA for wood contact, and FDA expectations in more depth in FDA and wooden kitchenware.
FSC chain of custody
FSC certification addresses legal and responsible timber sourcing through chain-of-custody certification, and it is available from some suppliers in the belt. The desk's position is specific: a certificate is verified by number lookup with the certification body, never claimed as held. If your program requires FSC material, say so in the brief, because it affects species sourcing and possibly lead time, and the desk will identify which route can support it and what documentation follows the material. The wider sourcing question, including legal-harvest documentation, is covered in our note on FSC and legal wood sourcing.
California Prop 65
Proposition 65 warning obligations in California depend on the finishes and adhesives involved, not on wood as such. Whether a specific finish system triggers a warning is an assessment your compliance adviser makes against the current list; the desk supplies the finish and adhesive identities on the spec sheet so that assessment rests on facts. We deliberately do not offer a Prop 65 verdict ourselves, because the list changes and the assessment is program-specific.
FTC Green Guides and environmental claims
Environmental marketing claims in the US are governed by the FTC Green Guides, and they are where otherwise careful programs get sloppy. Unqualified claims such as eco-friendly, biodegradable or compostable need qualification to match what the product actually is. Bamboo illustrates the trap: it is a fast-renewing plant, but finished bamboo panels involve adhesives, so a broad eco claim on a bamboo utensil can outrun the product. The same discipline applies to wood claims: describe the material and the finish system factually, and let the facts carry the message. Our notes on eco claims and the Green Guides and on bamboo utensil adhesives cover the details, and the material pages for bamboo utensils and non-toxic wooden utensils show the phrasing applied.
The map of obligations
| Rule | What it covers | Who handles it | What the desk supplies |
|---|---|---|---|
| Lacey Act | Plant-product declaration at US entry | Importer of record, via broker and CBP ABI | Species, origin basis and quantities from the spec sheet |
| FDA food-contact | Clean wood articles; finishes under 21 CFR 174-186 | Buyer confirms finish documentation | Finish system named on the spec sheet |
| LFGB | German food-contact framework | Buyer decides on testing | Reports where held, confirmed per program |
| FSC | Chain-of-custody for timber | Certification body verifies | Number lookup, never a claim of holding |
| Prop 65 | California warnings on finishes and adhesives | Buyer's compliance adviser | Finish and adhesive identities |
| FTC Green Guides | Environmental marketing claims | Buyer's marketing and counsel | Factual material descriptions to claim against |
How the desk phrases claims
Three things we do not do: invent test results, quote certificate numbers that have not been verified, or describe a product as certified. Language such as non-toxic is used to describe the material and finish system factually, solid wood finished with a food-contact oil, rather than as a certified claim, and we advise product-page wording in the same register. If you want that discipline applied to your line's copy and its compliance footing, send a brief with the markets you sell into, and the desk will confirm, in writing, which information flows from the program documents and which remains with your advisers.