Food Packaging Requirements: FDA Compliance Guide

If you're packaging food products, compliance isn't optional—it's the law. The Food and Drug Administration (FDA) has strict requirements for materials that contact food, and failing to comply can result in recalls, fines, and legal liability.

This guide breaks down everything you need to know about FDA-compliant food packaging.

Understanding FDA Food Contact Regulations

What the FDA Regulates

The FDA regulates any material that:

• Directly contacts food
• Could reasonably be expected to contact food
• Becomes part of food through contact

This includes:

• Primary packaging (boxes, bags, containers)
• Liners and coatings
• Inks and adhesives that contact food
• Labels on food-contact surfaces

Key Regulatory Framework

21 CFR (Code of Federal Regulations)

• Part 174-178: Indirect food additives
• Part 182-186: GRAS substances
• Part 170-171: Food additive petitions

Food Contact Notification (FCN)

• Modern pathway for new food contact materials
• Manufacturers submit safety data to FDA
• 120-day review process
• More common than petitions today

Food-Safe Packaging Materials

Paper and Paperboard

Paper products for food must meet:

• Purity standards (no harmful substances)
• Specific requirements for bleaching
• Heavy metal limits
• Migration limits for any coatings

Safe Options:

• Virgin kraft paperboard
• FDA-compliant recycled content
• Grease-resistant treatments (PFC-free preferred)
• Aqueous coatings

Avoid:

• Recycled paper with unknown content
• Papers with non-food-safe inks
• Unapproved coatings

Corrugated Cardboard

Requirements for corrugated food packaging:

• Outer liner: No specific requirements (no food contact)
• Inner liner: Must meet food-contact standards
• Adhesives: Must be food-safe if contact possible

Coatings and Liners

Common Food-Safe Coatings:

• Polyethylene (PE): Moisture barrier
• Polypropylene (PP): Heat and moisture resistant
• PLA (polylactic acid): Compostable option
• Aqueous coatings: Water-based barrier

Grease Resistance:

• Traditional PFCs being phased out
• New PFC-free alternatives available
• Must verify FDA compliance

Certification Requirements

What Certification Means

"FDA compliant" means materials meet:

• Composition requirements
• Testing requirements
• Good Manufacturing Practices (GMPs)
• Specific use conditions

Required Documentation

Suppliers should provide:

1. 1Letter of Compliance/Guarantee

- States materials meet FDA requirements

- References specific CFR sections

- Covers specific use conditions

1. 2Material Specifications

- Composition details

- Manufacturing process

- Testing certifications

1. 3Migration Testing (if applicable)

- Overall migration limits

- Specific migration limits

- Test conditions matching intended use

Important Certifications

Safe Quality Food (SQF)

• Recognized by GFSI
• Manufacturing quality standard
• Covers packaging facilities

BRC Global Standard

• Packaging and packaging materials
• International recognition
• Retailer requirements often cite BRC

Labeling Requirements

Required Information

Food packaging typically must display:

• Product identity
• Net quantity
• Manufacturer information
• Ingredient list
• Nutrition facts
• Allergen warnings

Placement Rules

• Principal Display Panel (PDP): Name, net weight
• Information Panel: Ingredients, nutrition, manufacturer
• Must be legible and conspicuous
• Size requirements based on package size

Common Labeling Mistakes

1. 1Missing allergen declarations
2. 2Incorrect net weight placement
3. 3Font size too small
4. 4Missing manufacturer address
5. 5Nutritional information errors

Types of Food Packaging Compliance

Direct Food Contact

For packaging touching food:

• All materials must be food-safe
• Inks must not migrate through
• Consider fat/oil/acid content
• Time and temperature factors

Indirect Food Contact

For outer packaging:

• Less stringent requirements
• Still consider migration potential
• Ink on inside of outer box matters

Functional Barriers

A layer preventing migration:

• Allows non-compliant outer materials
• Must be proven effective
• Adds complexity and cost

Special Considerations by Food Type

Dry Foods

• Lower migration risk
• Standard food-safe materials
• Moisture protection focus

Fatty/Oily Foods

• Higher migration potential
• Need appropriate barriers
• Grease resistance required
• More stringent testing

Acidic Foods

• Can increase migration
• Specific material requirements
• pH considerations

Hot Foods

• Temperature affects migration
• Heat-stable materials required
• Special testing conditions

Refrigerated/Frozen Foods

• Moisture resistance critical
• Cold temperature performance
• Condensation considerations

Bakery Packaging Specifics

Common Bakery Products

Cakes and Cupcakes:

• Window boxes with food-safe windows
• Grease-resistant base
• Venting for moisture

Cookies and Pastries:

• Food-safe ink critical
• Grease resistance for butter items
• Oxygen barrier for freshness

Bread Products:

• Moisture management
• Venting requirements
• Bag vs. box considerations

Bakery-Specific Requirements

• Grease barriers for butter/oil items
• Windows must be food-safe film
• Consider product moisture levels
• Shelf life requirements

Getting Compliant Packaging

What to Ask Suppliers

1. 1"Are your materials FDA compliant for direct food contact?"
2. 2"Can you provide a letter of compliance?"
3. 3"What CFR sections do your materials comply with?"
4. 4"Has the material been tested for my specific food type?"
5. 5"Are your inks food-safe?"
6. 6"Do you follow GMPs?"

Red Flags to Watch For

• Unable to provide documentation
• Vague "food safe" claims without specifics
• No reference to CFR sections
• Reluctance to discuss compliance
• Significantly lower prices than competitors

Common Compliance Questions

Q: Can I use regular custom boxes for food?

A: Not necessarily. Standard custom boxes may use materials or inks not intended for food contact. Always verify food-grade compliance.

Q: Is recycled cardboard food-safe?

A: It can be if sourced from controlled recycled streams and processed appropriately. Verify with supplier documentation.

Q: Do I need to test my packaging?

A: Testing depends on risk level. High-risk (fatty, acidic, hot) foods may need migration testing. Consult with your supplier and consider third-party testing for peace of mind.

Q: What if my food doesn't directly touch the box?

A: If there's a functional barrier (sealed inner bag), outer packaging requirements are less stringent. Document the barrier's effectiveness.

Working with Brisk Packaging

Our food packaging solutions include:

Standard Compliance:

• FDA-compliant materials
• Food-safe inks and coatings
• Letter of compliance included
• GMP-compliant manufacturing

Available Options:

• Grease-resistant coatings
• Custom window films
• Temperature-appropriate materials
• Various barrier options

Documentation Provided:

• Material compliance letters
• Specification sheets
• Certification copies upon request

We've helped hundreds of food businesses navigate packaging compliance. Our team understands the requirements and can guide you to the right solution.

Whether you're packaging cookies, cakes, prepared foods, or specialty products, we ensure your packaging meets FDA requirements while looking great and protecting your products.