What Certifications and Testing Are Required for Food Packaging?

Why Food Packaging Is Regulated Separately

Food packaging differs from ordinary product packaging. Packaging materials come into direct contact with food, and harmful substances in the materials may migrate into the food. For this reason, countries manage food contact materials as a separate category, with a standards system that is clearly different from that of industrial packaging and personal care packaging.

In China, packaging and printing companies that serve food clients are often asked: do you have test reports for food packaging? The test reports referred to here are compliance certificates issued in accordance with national mandatory standards.

Domestic Standard System: GB 4806 Series

The GB 4806 series is a national mandatory standard that specifically regulates food contact materials. Common ones include:

GB 4806.7-2023 Plastic Materials and Products for Food Contact. Covers plastic materials such as PE, PP, PET, and requires overall migration, specific migration, and sensory indicators to comply with the specified limits.

GB 4806.8-2022 Paper and Paperboard Materials and Products for Food Contact. This is the most frequently cited standard for paper packaging, with clear limits on lead, arsenic, fluorescent whitening agents, and microorganisms.

GB 9685-2016 Standard for the Use of Additives in Food Contact Materials and Products. Specifies which additives may be used, the maximum usage levels, and the upper limits for specific migration.

The GB 4806 series standards are mandatory, meaning that food contact materials entering the market must comply with the corresponding provisions; this is not a voluntary action by enterprises.

EU Regulatory System: EU 10/2011

Food packaging exported to the EU must comply with the EU Plastics Regulation for food contact materials, EU No 10/2011. This regulation establishes positive lists for monomers, additives, and starting substances used in plastics, and sets upper limits for Overall Migration Limit (OML) and Specific Migration Limit (SML).

For paper-based food contact materials, the EU also has specific national regulations of member states, such as German BfR and French DGCCRF. In practice, exporting companies often follow the testing items specified by their customers.

U.S. Standards System: FDA 21 CFR

Food contact materials for the U.S. market are regulated by the FDA, with the relevant regulations consolidated in 21 CFR Parts 170-199. Different dedicated sections cover various materials such as paper, plastics, coatings, adhesives, and inks.

FSC-certified paper does not equate to FDA compliance. What the FDA focuses on is not the forest origin, but the migration safety of the material when in contact with food.

Interpretation of Common Testing Items

Overall Migration Limit (OML): Under simulated conditions, the total amount of non-volatile substances that migrate from the material into the food simulant. The EU limit is typically 10 mg/dm².

Specific Migration Limit (SML): The migration upper limit for specific harmful substances (such as heavy metals, certain monomers), with each substance having its own SML value.

Sensory Requirements: After the packaging contacts food, it should not impart any off-odor or alter the color, aroma, or taste of the food. This is a mandatory testing item in standards such as GB 4806.8.

Microbiological Indicators: Limits for total bacterial colony count, coliform bacteria, and pathogenic bacteria in paper-based food packaging.

Heavy Metals and Fluorescent Whitening Agents: Restrictions on heavy metal elements such as lead, arsenic, and cadmium, as well as the use of fluorescent whitening agents in paper packaging.

How Suppliers and Brands Divide Responsibilities

Compliance responsibility for food packaging is not a one-sided matter. The food brand is responsible for the safety of the final food product, while the packaging supplier is responsible for material compliance.

The usual practice is as follows: the packaging supplier submits samples for inspection according to national or customer-specified standards and provides third-party test reports; the food brand clearly requires in the procurement contract that the supplier provide the corresponding reports and retain the valid versions; and small-batch compliance verification is carried out before new product launches.

For a packaging manufacturer, keeping an up-to-date GB 4806.8 test report for its main products is fundamental. If customers have export needs, corresponding international-version tests should also be conducted in accordance with EU 10/2011 or FDA 21 CFR.

Common Misconceptions

Misconception 1: A single test is valid long-term. Test reports typically apply to a specific batch and specific formulation. If the raw material supplier, printing process, or ink formulation changes, re-testing is required.

Misconception 2: All food packaging requires the same testing. The actual project depends on the food type (liquid, solid, dried fruit, oily food), contact method (direct/indirect), and usage temperature (room temperature/high-temperature retorting/microwave).

Misconception 3: Having a test report means full compliance. A test report only proves that the submitted sample is compliant; it cannot cover all production batches. Sustained compliance requires a stable supply chain and process control.

Procurement Recommendations

For procurement personnel at food brands, it is recommended that the following information be clearly specified at the inquiry stage: target market (domestic/EU/U.S.), food type and contact method, specific standard numbers to be referenced, validity period of test reports, and whether batch-by-batch testing is required. The earlier this information is aligned, the more controllable subsequent testing costs and timelines will be.

For packaging suppliers, establishing a test report library covering core products, categorized by material (white cardboard, corrugated paper, plastic, composite materials) and food type, can significantly improve customer engagement efficiency.