Food-Grade Packaging Material Safety: FDA, EU and China Standards

Food packaging is subject to stricter material safety requirements than general consumer packaging. Brands sourcing custom food packaging from a China manufacturer need to understand which materials are permitted, what migration testing means, and how to obtain compliance documentation that satisfies their domestic market regulators.

Defining Food-Grade Packaging

A food-grade material is one that does not transfer harmful substances to food at levels above regulatory limits under normal use conditions. In practice, this means:

• The raw materials (paper, film, inks, adhesives, coatings) must be from approved substance lists
• Overall migration—total substances transferred to food simulant—must not exceed limits
• Specific substances (heavy metals, certain plasticisers, photoinitiators) must individually stay below thresholds

Note that a packaging material being food-grade does not mean any printing ink applied to it is automatically food-safe. Inks, varnishes and adhesives must each be separately evaluated.

Regulatory Frameworks by Market

United States (FDA)

In the US, food contact materials are regulated under 21 CFR (Code of Federal Regulations). Paper and board: 21 CFR 176.170 / 176.180. Adhesives: 21 CFR 175.105. Coatings: 21 CFR 176.300. Manufacturers must use substances listed in these regulations or obtain a Food Contact Notification (FCN).

European Union (EU)

EU food contact materials are governed by Regulation EC 1935/2004 (framework) and specific measures for plastics (EU 10/2011), paper (in development), inks and adhesives. EU 10/2011 contains a positive list of monomers and additives permitted in plastic food contact materials. Overall migration limit (OML): 10mg/dm² (or 60mg/kg food simulant). Specific migration limits (SML) apply to listed substances.

China (GB Standards)

In China, food packaging is regulated under GB 4806.x standards (part of the GB 4806 family on food contact materials). GB 4806.8 covers paper and board; GB 4806.6 covers plastic resin; GB 4806.7 covers plastic packaging. Compliance with Chinese GB standards is required for products sold in the Chinese domestic market and is increasingly expected by Chinese export manufacturers as a quality baseline.

Common Food Packaging Materials and Their Status

Migration Testing

Migration testing measures how much of a substance transfers from the packaging to a food simulant under standardised conditions. Simulants used in EU 10/2011:

• Simulant A (water): 10% ethanol — for aqueous, non-acidic food
• Simulant B (3% acetic acid): for acidic food (pH <4.5)
• Simulant C (20% ethanol): for alcoholic food up to 20% ABV
• Simulant D1 (50% ethanol): for alcoholic food above 20% ABV
• Simulant D2 (vegetable oil): for fatty food

Standard test conditions: 10 days at 40°C for ambient-use packaging. High-temperature conditions apply for microwave or hot-fill applications.

What to Request from BestPackFactory

When ordering food packaging, request the following documentation:

• Declaration of Compliance (DoC) confirming materials meet applicable regulatory standards
• Third-party test reports from a recognised laboratory (SGS, Intertek, BV) for overall migration and any specific migration if required by your market
• Material data sheets for all film structures, inks and adhesives used
• Confirmation that printing inks are not in direct food contact (all inks on external surfaces)