How food contact compliance works
Food contact rules do not certify a container once for all markets. Each market sets rules for the substances and materials that may touch food and the conditions under which they may be used. Compliance is shown by a chain of documents: the resin supplier's statement for the raw material, the plant's declaration for the finished article, and test reports from a third-party lab that measure migration under conditions matching the real use. Certificates and test reports are issued to partner plants or to your brand per project and verified by the desk; Lidwell does not hold them. Whether a given product meets a given law is a question for your test lab or counsel.
United States: FDA 21 CFR
The FDA rules on indirect food additives sit in 21 CFR parts 174 to 178. Olefin polymers, including PP and PE, are covered by 21 CFR 177.1520, which sets specifications such as density, a melting point range of 160-180 degrees C for PP, and limits on hexane extractables. Use is tied to conditions of use, designated A to H in 21 CFR 176.170(c), which run from high temperature heat-sterilized use to frozen storage. The FDA does not issue approvals for finished containers; the correct statement is that its material complies with 21 CFR 177.1520 under stated conditions of use, per supplier declaration or test report. Paper and board coatings are covered under 21 CFR 176.170 and related sections.
European Union: 1935/2004 and 10/2011
Regulation (EC) 1935/2004 is the framework for all food contact materials: they must not transfer constituents to food in quantities that could endanger health or change the food unacceptably, and they must be traceable. Regulation (EU) 10/2011 adds specific rules for plastics: an authorised substance list, an overall migration limit of 10 mg/dm2 or 60 mg/kg of food simulant, specific migration limits for listed substances, and a written declaration of compliance. A resin supplier's declaration covers an intermediate material, so the finished container still needs verification, usually overall and specific migration testing on the actual article.
Germany: LFGB tests
Buyers selling into Germany often ask for tests under LFGB sections 30 and 31, together with BfR recommendations for materials not fully covered by EU rules. These are test reports on a specific sample, not a certification, so the product is described as tested to LFGB per report.
China: GB 4806 series
China's national food safety standards for food contact materials include GB 4806.1 (general requirements), GB 4806.6 (resins), GB 4806.7-2023 (plastic materials and articles, the new edition) and GB 4806.8 (paper and board). Partner plants selling domestically work to these standards, and a GB 4806 report is a useful indicator of a plant's discipline, though it does not replace tests for US or EU destinations.
Documents to request by market
| Market | Framework | Documents to request | Wording on the spec |
|---|---|---|---|
| United States | 21 CFR 174-178, 177.1520 for PP | Resin letter, supplier declaration with conditions of use, extraction test where required | Complies with 21 CFR 177.1520 per supplier declaration |
| European Union | 1935/2004, 10/2011 | Declaration of compliance, overall and specific migration report on the article | Tested to EU 10/2011 per report |
| Germany | LFGB 30 and 31, BfR | LFGB test report on the article, including sensory tests where relevant | Tested to LFGB per report |
| China | GB 4806.1, 4806.7-2023, 4806.8 | GB 4806 test report for the material and article | Tested to GB 4806.7 per report |
| Paper items, US | 21 CFR 176.170, state PFAS rules | Board declaration, statement on intentionally added PFAS, total fluorine test where required | No intentionally added PFAS per supplier declaration |
Matching tests to real use
Migration tests are run with simulants and conditions chosen for the intended use: time, temperature and food type. A container tested only for cold storage is not covered for hot fill or reheating. The desk writes the intended use into the specification first, then agrees the test plan with the lab. Microwave use is stated per supplier marking, with the lid removed where marked, and checked in a heating test on the sample. PVC is kept out of heated food use entirely. See food contact safety and testing and inspection.
Wording to avoid
Claims that present a regulator or a test standard as a certification, or that promise a container contains no harmful substances at all, are inaccurate or unprovable and create risk on listings and packs. Use the qualified wording in the table instead, and keep the report number on file. The compliance checklist covers the full set; send your destination markets with the quote form and the desk lists the documents per item.