Food-Grade Packaging Requirements: What Brands Need to Know in 2026

Food packaging in the United States operates within a regulatory framework that most brand owners understand at a surface level but few have internalized in operational detail. This matters because the consequences of non-compliant food packaging range from consumer safety incidents to FDA enforcement action, product recall, and the brand trust damage that follows.

This guide provides a substantive overview of U.S. food-grade packaging requirements, covering the regulatory framework, material compliance documentation, labeling standards, and practical procurement implications for food brands at any scale.

The Regulatory Framework: FDA and Food Packaging

Food packaging in the U.S. is regulated primarily by the FDA (Food and Drug Administration) under the Federal Food, Drug, and Cosmetic Act (FD&C Act). The FDA’s regulatory approach to food packaging focuses on food contact substances, materials that come into direct or indirect contact with food products.

Indirect vs. Direct Food Contact

FDA regulations distinguish between:

• Direct food contact materials: packaging materials in direct contact with food (the inner surface of a food pouch, the interior of a food container)
• Indirect food contact materials: materials that may contact food only incidentally (outer corrugated boxes, secondary packaging)

Direct food contact materials face the most stringent regulatory scrutiny, as chemical migration from packaging into food is a primary food safety concern.

FDA 21 CFR: The Core Regulatory Text

Title 21 of the Code of Federal Regulations (CFR) governs food safety, and several parts are directly relevant to packaging:

21 CFR Part 177: Polymers

Part 177 establishes specifications for polymers intended for use in food contact articles. This covers the plastic resins, films, and coatings used in direct food contact flexible packaging, including the polyethylene inner layers of Mylar bags, polypropylene pouches, and plastic containers. Each polymer formulation used in food contact applications must comply with an applicable FCN (Food Contact Notification) or the relevant 21 CFR listing.

21 CFR Part 176: Paper and Paperboard

Part 176 covers paper and paperboard components of food contact articles, including the paper wraps used in Kraft food packaging, the interior liners of corrugated food boxes, and the base papers of laminated food pouches. Specifications include limits on extractable substances and requirements for specific additives.

21 CFR Part 178: Adjuvants and Production Aids

Part 178 covers the inks, adhesives, coatings, and processing aids used in manufacturing food contact materials. Printing inks applied to the exterior of food packaging, even when not in direct food contact, are subject to migration limits if they can transfer to the food-contacting surface.

Here’s what most buyers overlook: it’s not enough to use a food-grade packaging substrate. The printing inks, lamination adhesives, and coatings applied to that substrate must also comply with applicable food contact regulations. A food-safe film printed with non-food-safe inks is not food-safe packaging.

EU Regulation 10/2011: Relevance for U.S. Export Brands

U.S. food brands exporting to European markets, or those sourcing packaging manufactured in Europe, should be aware of EU Regulation No. 10/2011 on plastic materials and articles intended to contact food. This regulation establishes an EU-wide positive list of authorized monomers, additives, and starting substances for plastics in food contact applications.

While EU regulation does not apply to packaging sold only in the U.S., many packaging suppliers use EU Regulation 10/2011 compliance as a global standard for their food-grade materials, providing a useful baseline for verification.

Documentation Requirements for Food Packaging Buyers

Buyers sourcing food packaging should request and retain the following compliance documentation from their suppliers:

Certificate of Compliance (CoC)

A written declaration from the packaging supplier or material manufacturer confirming that the packaging materials comply with applicable food contact regulations (typically FDA 21 CFR Parts 176–178 and/or EU Regulation 10/2011). The CoC should reference the specific regulations and the specific materials being supplied.

Food Contact Notification (FCN) or GRAS Status

For novel food contact materials or formulations not covered by existing 21 CFR listings, manufacturers must file a Food Contact Notification with the FDA (or establish GRAS, Generally Recognized as Safe, status). Buyers of innovative packaging materials should verify this status with their supplier.

Migration Testing Data

For high-risk applications (infant food, products with high fat or acid content, products with long shelf life), migration testing data demonstrating that chemical migration from packaging to food product stays within regulatory limits is best practice, and sometimes a retailer or institutional buyer requirement.

Labeling Requirements for Food Packaging

FDA food labeling requirements are extensive and governed primarily by 21 CFR Part 101. Key elements that affect packaging design and specification include:

• Statement of identity: the product name on the principal display panel
• Net quantity of contents: in both U.S. customary and metric units
• Nutrition facts panel: format, font size, and placement requirements are highly specific
• Ingredient list: all ingredients in descending order of weight, with specific naming requirements
• Allergen declaration: major food allergens must be disclosed in a ‘Contains’ statement or in the ingredient list
• Manufacturer/distributor information: name and address

The FDA’s guidance documents on food labeling (available at fda.gov) are the authoritative reference. For complex labeling questions, particularly those involving nutrition claims, health claims, or structure/function claims, consultation with a regulatory specialist is advisable.

Practical Procurement Guidance

For food brand buyers sourcing packaging, the practical workflow for ensuring food-grade compliance is:

• Step 1: Identify all packaging components that will contact food directly or indirectly
• Step 2: Request CoC documentation from each supplier for each material
• Step 3: Review CoC references against applicable 21 CFR parts
• Step 4: Request migration testing data for high-risk applications
• Step 5: Retain documentation in a compliance file accessible to quality and regulatory teams