SolutionA paper bag and a food-grade paper bag look identical in a photo and on a sample table. What separates them is not the weight, the colour or the price — it is the fibre source, the additives, the barrier and the ink, and whether anyone can produce the paperwork to prove it. If your packaging touches food, the specification conversation is a compliance conversation. This guide covers what actually matters, by market and by product.
The short answer
- What market will you sell in? That decides which framework applies — EU, US or China — and they are not interchangeable.
- Does the paper touch the food directly, or is there an inner liner? Direct contact raises the requirement level sharply.
- Is the fibre virgin and food-grade? This is the first thing to confirm, before design, before price.
- Can the supplier give you a Declaration of Compliance and migration test reports? If not, keep looking, whatever the price.
The four regulatory frameworks you will meet
| Market | Main instruments | What it means in practice |
|---|---|---|
| European Union | Regulation (EC) 1935/2004 (framework), GMP Regulation (EC) 2023/2006, national rules such as German BfR Recommendation XXXVI for paper | Supplier must issue a written Declaration of Compliance. Migration limits apply, and there are specific expectations on optical brighteners and mineral oil residues. |
| United States | FDA 21 CFR Part 176 (paper and paperboard components), Part 177 (polymer coatings), Food Contact Notifications | Compliance is about the components being approved substances, evidenced by a supplier declaration. The FDA does not issue food-grade certificates. |
| China | GB 4806.1 (general safety), GB 4806.8 (paper and paperboard in contact with food), GB 9685 (additives) | Domestic sales require testing to the GB standards; the same applies if your customer is sourcing for the Chinese market. |
| Other markets | Often modelled on EU or US rules (Mercosur, GCC, ASEAN) | Ask your importer which local standard applies before design is frozen. |
The practical consequence: one specification does not necessarily serve every market. If you sell the same box in the EU and the US, the paper, coating and ink choices may need to differ — or be selected conservatively enough to satisfy both. Raise this at the enquiry stage, not after artwork is approved.
Direct versus indirect contact
This distinction drives most of the cost and most of the risk.
Direct contact
The paper surface touches the food — a takeaway bag holding unwrapped bread, a bakery bag, a food tray. The sheet itself must be a food-grade material, the ink must not migrate through, and the paperwork must cover the exact structure. This is the highest requirement level.
Indirect contact
The food is wrapped or sleeved first, or sits in its own liner inside a paper box — pizza boxes, shipping cartons, an outer gift box around a sealed inner pack. Requirements are lighter, often satisfied by a barrier between the food and the board. Many buyers over-specify here and pay more than they need to; a few under-specify and get caught out.
If you are unsure which category you fall into, describe the actual pack construction — what is wrapped in what, in what order — and it can usually be settled in one exchange.
Fibre, brighteners and mineral oil
Three issues come up again and again with paper in food contact:
- Virgin versus recycled fibre. Recycled pulp is cheaper and widely used for indirect contact. For direct contact it is hard to control, because recovered fibre carries residues from whatever was printed or coated on it originally. Direct-contact food packaging generally specifies virgin food-grade board.
- Optical brightening agents (OBAs). OBAs make a sheet look whiter and are common in office and general retail paper. In food contact applications they are restricted or prohibited in several markets, including the EU. Bright white does not mean cleaner — ask specifically whether the board contains optical brighteners.
- Mineral oil hydrocarbons (MOSH/MOAH). These can migrate from recycled fibre and from conventional offset inks. They are a live regulatory topic in Europe and reason enough to keep recycled board away from direct contact, or to place a functional barrier between the board and the food.
Grease, moisture and heat: choosing the barrier
Most food packaging failures are not chemical, they are functional — the bag soaks through, the box goes soft, the print smears. The barrier choice is driven by the food, the temperature and the holding time.
| Requirement | Common solution | Notes |
|---|---|---|
| Grease resistance only | Greaseproof (densified) paper, or a fluoro-free grease barrier coating | No lamination needed; keeps the package recyclable in the paper stream |
| Grease + light moisture | Water-based barrier coating | Recyclable, less glossy, good for bakery and dry snacks |
| Moisture and liquid | PE lamination, or PLA for compostable programmes | PE is the workhorse; PLA suits compostable positioning at a higher cost |
| Hot food, short holding | Coated board or a lined board with venting | Vents matter as much as the coating — trapped steam destroys the structure |
| Long shelf life / aroma barrier | Aluminium foil or high-barrier film liner | Used inside a paper outer; the food contact layer becomes the film |
Inks and printing on food packaging
Printed logos on food packaging are a migration pathway, and this is where well-meaning projects go wrong:
- Conventional offset and UV inks are formulated for graphic print, not food contact. UV systems carry specific photoinitiator migration risk.
- Low-migration ink systems are designed for food packaging and are the direct answer where print is near the food surface.
- A functional barrier — typically PE or PLA lamination on the food side — lets you print conventionally on the outside face while the barrier keeps migration within limits. This is the usual arrangement for branded takeaway and bakery packaging.
Whatever the route, the build needs to be declared: board, coating, ink system and adhesive, each with its own compliance statement. See our printing guide for how each method behaves on paper.
Five mistakes that cost buyers real money
- Treating FSC as a food safety certificate. FSC is about forest management. It says nothing about food contact. See our FSC guide for what it does cover.
- Accepting an "FDA certificate". The FDA does not issue them for paper packaging. What you want is a component-level compliance declaration.
- Using recycled stock for direct contact because the sample looked fine — then discovering the mineral oil question at customs or at the retailer's audit.
- Designing the artwork before checking the ink system. Re-plating a food-contact job because the ink was wrong is an expensive way to learn this.
- Chasing paperwork after production. Declarations and test reports should exist at sample stage. A supplier who cannot produce them then will not produce them later.
Your pre-order checklist
Ask these seven questions before you approve a food-contact specification:
- Which market(s) will this packaging be sold in?
- Is the paper in direct or indirect contact with the food?
- Is the board virgin food-grade stock — and is it free of optical brighteners?
- Can you provide a Declaration of Compliance for board, coating, ink and adhesive?
- What migration testing has been done on this exact structure?
- What grease, moisture and heat resistance does the build deliver, and how was it tested?
- Which food safety system certification does the manufacturing site hold?
How we work on food packaging
We are a custom paper packaging manufacturer based in Quanzhou, China. Food contact orders are run on our own production lines, and our factory holds the manufacturing certifications — including FSC, ISO 9001, ISO 22000 and BSCI — and issues the declarations and test reports for the material. Our QC team stays on site through the run and checks each batch against the approved sample, sending you photos at every stage rather than a summary at the end.
Tell us the food, the market and the pack construction. You get a written specification stating the board grade, barrier, ink system and the documents we will supply, with a free pre-production sample in about 7 days and MOQ from 5,000 pcs.
Food packaging questions buyers ask us
Does FSC certification mean the paper is food-safe?
No. FSC certifies that fibre comes from responsibly managed forests. It says nothing about whether the sheet is approved for food contact. Food safety depends on the fibre source — virgin rather than recycled — the additives used, the barrier layer and the inks. Ask for the food contact declaration separately from the FSC certificate.
Can recycled paper be used for food packaging?
It can be used for indirect contact — an outer box that never touches food — and some markets allow recycled fibre behind a functional barrier layer. For direct food contact, recycled fibre carries risks that are hard to control, including mineral oil residues from printing inks in the recovered waste stream. Most direct-contact food packaging specifies virgin food-grade board.
What is a Declaration of Compliance and do I need one?
A Declaration of Compliance (DoC) is the supplier's written statement that a material complies with the relevant food contact regulation, naming the regulation and any migration limits. In the EU it is a legal requirement for food contact materials under Regulation (EC) 1935/2004. Most serious buyers now require one for every food-contact component — board, coating, ink and adhesive.
Is there such a thing as an FDA food-grade certificate?
Not in the way most buyers imagine. The US FDA does not issue food-grade certificates for paper packaging. What exists is compliance with FDA requirements, typically under 21 CFR Part 176 for paper and paperboard components, supported by a supplier declaration of compliance or a Food Contact Notification. Be cautious of any supplier offering an FDA certificate as a document.
What is the difference between greaseproof and grease-resistant paper?
Greaseproof paper is densified during manufacture so oil penetrates slowly — it resists grease without a coating, but offers limited water resistance. Grease-resistant paper usually means a sheet with a barrier coating, PE or PLA lamination or a silicone treatment, tuned to a specific grease resistance level. The right choice depends on the food, the temperature and the holding time, so test with the actual product.
Do printed logos need special inks for food packaging?
Yes, if the print is on or near the food contact surface. Standard offset and UV inks can migrate, and UV inks carry photoinitiator risk. Options are low-migration ink systems, or placing a functional barrier between the print and the food — typically PE or PLA lamination. In practice, print goes on the outside face and the barrier sits on the food side; confirm the build with your supplier before printing.
What documents should I receive before production?
For a direct food contact paper package: the board supplier's declaration of compliance naming the applicable regulation, migration test reports for the finished structure, a statement on optical brighteners and mineral oil, the ink system declaration, and the factory's food safety system certificate such as ISO 22000 or BRCGS Packaging Materials. Ask for the documents at sample stage, not after the container has shipped.
Send the food and the market — we will build the compliant spec
Tell us what the packaging holds, where it will be sold and how it is constructed. You get the board grade, barrier and ink system in writing, with the declarations and test reports behind them.
Related products
- Custom Kraft Paper Bags— food-contact kraft, printed 1–8 colours
- Custom Corrugated Boxes— food-grade pizza and takeaway boxes
More buying guides
- FSC® Certification: What Buyers Need to Know— sustainability
- Paper Bag GSM Explained: Choosing the Right Paper Weight— materials
- How to Custom Print Paper Bags— printing
- What Drives a Custom Paper Bag Price?— costing