How to Comply with Food Contact Regulations

Food is seldom safe from contaminants, they can be from human error or hazardous materials. Food contact materials such as cutlery, crockery, cartons, packaging, and kitchen equipment often contain microorganisms and chemicals which can detract from food quality and make it unfit for consumption. When this happens, food fails to meet the requirements set out by global governing bodies in the Food & Beverage industry.

Food contact materials (FCM) are designed with two specific goals in mind:

  • To protect food from microorganisms
  • To make consumption, handling, transport, purchase, and the sale of food hygienic and easy

When they fail to provide these benefits, FCMs become a danger to quality in food manufacturing.

Understanding global food contact regulations

European Union

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The European Union has some very stringent requirements when it comes to the usage and monitoring of food contact materials. According to EU regulations, any FCM, be it glass, metal, plastic, ceramic, paper, silicone, cardboard, sponge, wood, ink or any other material, must be designed in such a way as to preserve the natural constituency of food. Any food contact material that changes food consistency (flavor, aroma, texture or color) in an unacceptable way must adhere to the most stringent safety evaluation by FCM manufacturers.

Additionally, EU regulations expect a declaration of compliance (DOC) from FCM manufacturers, stating that they followed all EU regulations. Labeling is another factor that the EU considers of primary importance. Any materials that have not yet come into contact with food, but are expected to (cutlery, crockery, and kitchen equipment), must be mentioned on the packaging with the words ‘for food contact’.


It isn’t just the EU which has such strict rules concerning food contact materials. The United States Food and Drug Administration has also laid out rules in this regard. According to the Food, Drug and Cosmetic Act (FD&C Act) and Title 21 Code of Federal Regulations, all FCMs qualify as indirect food additives and must be pre-recognized and pre-approved by the FDA in order to be used in manufacturing food contact materials. Only substances defined by the FDA as food-safe can be used and must be completely free of any contaminants in order to be suitable for preserving food quality in manufacturing the food items it is intended for.

Additionally, according to FDA regulations, a company wishing to use any new FCM in their food processing must submit a notification to the FDA, informing them of their intent to do so.

NHFPC, China

The Chinese National Health and Family Planning Commission also has similar regulations to those of the EU and FDA. The regulatory body has listed 53 food safety standards, many of which pertain to the usage of food contact materials.

Products, when sold, must be appropriately labeled with information regarding materials used as FCMs. Information related to items used during consumption also needs to be updated on the product label.

When it comes to substances which qualify as sanctioned FCMs, the regulations don’t cover materials that fall under the categories of F&B-related detergents, disinfectants, and public water-transporting facilities. The rules regarding these are different and fall under other regulations.

Food Standards in Australia and New Zealand

FSANZ states that any food contact material used must not have any physical effect on the food it is intended for and must help retain the same food consistency during the production process. Additionally, FSANZ also regulates materials used for packaging and states that no materials should be used which could cause harm to consumers by direct contact (touch or smell).

Additionally, the regulatory body stipulated specific safety limits for FCMs to be implemented in food packaging, processing, and transport. Companies are expected to conduct safety testing to verify the safety and quality of these substances.


When it comes to food contact material traceability, all organizations place special emphasis on implementing stringent and comprehensive procedures to enable historical tracking of FCM quality and safety along the entire production chain, from raw material procurement to final food consumption. This traceability system needs to be set up to identify and prevent cases of potential migration.

Rules regarding migration

Food contact materials contain a variety of substances including starting substances, monomers, polymer production aids and additives, each of which may contain impurities in the form of microorganisms and chemicals. When these impurities transfer to food on contact, they degrade food quality and also create conditions which may result in adverse health effects on consumers.

Global regulations require immediate identification and prevention of migration through comprehensive safety evaluation. FCM manufactures are required to evaluate the level at which and conditions under which substances can trigger migration.

Tests need to be designed to evaluate the following factors:

  • Potential toxicity
  • Consumer’s exposure to food contact materials
  • Migration rate of chemicals and microorganisms

Through this compliance testing, companies need to measure:

  • Specific migration limits: This helps analyze the amount of migration that is triggered by specific substances.
  • Overall migration limits: This helps measure the quantity and toxicity of chemicals that migrate to food.

What can companies do to mitigate migration and fulfill compliance requirements?

Food manufacturers, food processing agencies, and manufacturers of food contact materials can engage in the following activities to ensure that they meet compliance requirements stipulated by governing bodies:

Conduct proactive safety tests at all points across the supply chain
Contamination and migration can happen at any point across the supply chain. In order to ensure standardized quality across the spectrum, companies need to set up standardized safety tests which can be conducted at key points of the supply chain.

Starting from whetting suppliers of raw materials to identifying the conditions under which the chances of migration are the greatest can go a long way in maintaining food quality. Surrogate contamination testing is another way to preserve food quality and safety.

Stay updated about emerging practices in food safety
These days, scientists and manufacturers in the F&B industry are integrating various disciplines such as behavioral sciences and management with food science. There are many online repositories and databases available which help connect various F&B industry players to their global counterparts. Companies can now access the most recent trends, standards, benchmarks, and protocols in the industry.

In addition, these online repositories allow companies to access regulatory information as well as provide companies the opportunity to update their own practices, material lists and more.

Seek approval from governing bodies for usage of new contact materials
Companies are expected to provide up-to-date information regarding processes, materials used, and operational standards to relevant governing bodies and other members of the supply chain.

If there is any new food contact material that is available for use or a substance that can have multiple/alternative uses, it’s important to disclose this information and seek protective legislation from relevant governing bodies.

Use green materials for food packaging and processing
Today, we are witnessing emerging discoveries and developments in FCM manufacturing and usage. For example, polycarbonate used in baby bottles is being replaced by the polymer Tritan for its lack of estrogenic activity in the body. Some companies around the world are choosing to use Provalin caskets in glass bottles, as they have a lesser migration rate than PVC.

Scientists are working on developing BPA-free and EA-free material to be used as lining for food packaging. Additionally, recycled food contact materials are also finding increased use in the industry, as they are much safer and do not require sanctioning from governing bodies.

Companies can choose to switch over to these safer and greener alternatives for their food contact material needs.

When companies make proactive changes to their food processing, packaging, and transportation strategy, they will begin to see significant changes in food safety and quality.

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