Food-contact suitability is application-specific. The packaging business should identify every component that can contact the food directly or indirectly, obtain the applicable supplier documentation, and confirm that the intended food, contact time, temperature and processing conditions fall within its scope. This page is general selection guidance; final legal and technical approval must use current requirements and competent advice for the actual application.
Build a component-level food-contact file
| Record | Questions to answer | Typical owner |
|---|---|---|
| Component specification | Which bottle, pouch, cap, liner, valve, coating, ink or adhesive can contact the product? | Packaging / procurement |
| Supplier declaration | Which product reference, material, site, food types and use conditions are covered? | Quality / regulatory |
| Application brief | What is the food, fill process, temperature, contact time, storage and intended reuse? | Technical / product development |
| Trial and shelf-life evidence | Did the complete pack remain acceptable through filling, storage and distribution? | Quality / production |
| Change control | Which supplier, material, colour, layer, process or site changes require reassessment? | Procurement / quality |
What evidence is needed for food-contact packaging in the UK?
Use packaging intended for the food-contact application and retain the written evidence required for the relevant material and use. The evidence should identify the supplier, exact article or material, applicable requirements and conditions or restrictions of use.
For plastics and other materials subject to specific measures, a declaration of compliance may be required. Match it to the exact bottle, pouch, closure, liner, coating or film rather than a generic material family.
Does a food-contact declaration cover every product and filling condition?
No. A declaration applies only within its stated scope and conditions. Review the food types, contact time, temperature, surface-area relationship, repeated-use status and any functional-barrier or migration restrictions. A cold-filled dry product and a hot-filled fatty product may not fall within the same evidence basis.
Ask the supplier to clarify gaps before trials or artwork approval; do not extend the declaration by assumption.
How should recycled-content food packaging be reviewed?
Review food-contact suitability and recycled-content evidence as separate but connected controls. Confirm that the exact recycled material route and article are authorised or compliant for the intended use, and that the declared percentage and calculation scope match the component supplied.
Also test colour, odour, clarity, mechanical behaviour and line performance where these are relevant to the product and pack. Recycled content does not itself prove food-contact suitability or recyclability.
What changes can invalidate a food-contact approval?
A change to material, additive, colour, recycled-content source, layer, coating, adhesive, ink, manufacturing site, process or intended use can require review. The same applies when contact time, temperature, food type or storage conditions change.
Supplier change notification should be linked to the approved specification so production is not supplied with a technically different article under an unchanged commercial description.
What should a manufacturer send with a food-packaging enquiry?
Send the food type, relevant composition or hazards, fill temperature, contact and storage conditions, target shelf life, pack size, closure or seal method, processing method, annual quantity and current packaging. Include existing declarations, drawings, artwork and representative product and pack samples where possible.
Lancing can then identify candidate packaging and the evidence or trials still required; the final food-safety approval remains with the responsible business.
Before production approval
- Confirm the declaration and supplier product code match the delivered component.
- Record the intended food, contact time, temperature and processing conditions.
- Test the complete pack, not only the main container material.
- Retain approved samples, trial records and current documents.
- Use a competent regulatory review where the application or evidence is uncertain.
Authoritative references
These sources are starting points for the applicable UK requirement or disposal context. The current version, territorial scope and exact packaging application should be checked when a decision is approved.
- Food Standards Agency: packaging and labelling guidance
- Food Standards Agency: food-contact materials regulations
- Food Standards Agency: biobased food-contact material guide