Food-Grade Packaging: What You Need to Know

Food-grade packaging is a critical component of the food supply chain. Whether you are shipping fresh produce, dry goods, frozen items, or prepared foods, the packaging must meet strict safety standards to protect consumers and comply with federal regulations. This guide covers the essential requirements every food business needs to understand.

FDA Regulations Overview

In the United States, the Food and Drug Administration (FDA) regulates all materials that come into contact with food. Under the Federal Food, Drug, and Cosmetic Act (FD&C Act) and the Food Safety Modernization Act (FSMA), food packaging must be made from materials that are safe, clean, and will not transfer harmful substances to the food they contain.

The FDA does not "approve" food packaging materials in the traditional sense. Instead, it maintains a list of substances that are Generally Recognized as Safe (GRAS) for food contact use. Packaging manufacturers are responsible for ensuring their products comply with these regulations using only approved materials and manufacturing processes.

Key FDA Regulatory Requirements

• All food contact materials must be made from FDA-approved substances (21 CFR Parts 170-199)
• Packaging must not impart odor, color, or taste to the food
• Materials must be suitable for the intended conditions of use (temperature, duration, food type)
• Good Manufacturing Practices (GMPs) must be followed throughout production
• Traceability and documentation must be maintained for all packaging materials

Direct vs. Indirect Food Contact

Understanding the distinction between direct and indirect food contact is essential for selecting the right packaging materials and meeting regulatory requirements.

Direct Food Contact

Direct food contact packaging touches the food product itself. This includes inner liners, wraps, trays, and any surface that directly touches the food. Direct contact materials must meet the strictest FDA standards, including migration testing to ensure harmful substances do not transfer to the food under expected conditions of use.

Indirect Food Contact

Indirect food contact packaging does not touch the food directly but is in close proximity. The outer corrugated box that holds individually wrapped food products is an example. While indirect contact packaging has less stringent requirements than direct contact materials, it must still be clean, free from contamination, and made from materials that will not compromise food safety.

Contamination Prevention

Preventing contamination is the core purpose of food-grade packaging requirements. Contamination can be physical (foreign objects), chemical (substances migrating from packaging), or biological (bacteria, mold, pests).

• Physical contamination: Ensure packaging is free from loose fibers, staples, splinters, and foreign particles
• Chemical contamination: Use only FDA-approved inks, adhesives, and coatings — avoid recycled materials with unknown chemical histories for direct contact
• Biological contamination: Store packaging in clean, dry, pest-free environments and inspect before use
• Cross-contamination: Separate food-grade packaging from non-food packaging and chemicals in storage and transport

Special Considerations for Corrugated Boxes

Corrugated boxes used in food applications require special attention. The inks and adhesives used in manufacturing must be food-safe. Boxes made from recycled fiber may contain trace contaminants from previous uses and are generally not suitable for direct food contact without an approved inner liner. Virgin fiber boxes or those with food-grade poly liners are the safest choice for direct and near-contact applications.

Certification Requirements

While the FDA does not certify food packaging directly, several industry certification programs help demonstrate compliance and build buyer confidence.

• SQF (Safe Quality Food) Certification: Recognized by the Global Food Safety Initiative (GFSI), covers packaging manufacturing
• BRC Packaging Materials Certification: A GFSI-recognized standard specific to packaging materials
• ISO 22000: International food safety management system standard applicable to packaging suppliers
• AIB International: Provides food safety auditing and certification for packaging facilities
• FDA Facility Registration: Required for facilities that manufacture, process, pack, or hold food-contact materials

Material Considerations for Food Packaging

Different food types and storage conditions require different packaging material properties. Selecting the right material involves matching the food's requirements with the packaging's capabilities.

Material Properties to Consider

• Moisture barrier: Essential for dry goods, frozen foods, and hygroscopic products
• Oxygen barrier: Critical for extending shelf life of perishable and oxidation-sensitive foods
• Grease resistance: Required for fatty and oily foods to prevent saturation and failure
• Temperature resistance: Must withstand the full range of expected temperatures from freezing to heating
• Structural strength: Must maintain integrity under the weight and handling conditions of the supply chain

Labeling Requirements

Food packaging labeling is regulated by the FDA and must include specific information presented in a prescribed format. While the inner package typically carries the nutrition facts and ingredient list, the outer shipping container has its own labeling requirements.

• Product name and description must be clearly visible on shipping containers
• Net weight or count must be stated accurately
• Manufacturer or distributor name and address are required
• Lot codes and date coding enable traceability and recall management
• Allergen declarations must be prominently displayed on consumer-facing packaging
• Country of origin labeling is required for imported food products

Using Corrugated Boxes for Food Applications

Corrugated boxes are widely used in the food industry for shipping and storing both raw ingredients and finished products. When using corrugated boxes for food applications, ensure they are sourced from a supplier that understands food-grade requirements and can provide appropriate documentation.

For direct food contact, use virgin fiber boxes with food-grade poly liners. For indirect contact (shipping cases holding individually packaged items), clean used boxes in good condition may be acceptable — but always verify with your food safety team and regulatory requirements. When in doubt, prioritize food safety over cost savings.

Temperature-Controlled Packaging Considerations

Many food products require temperature-controlled packaging throughout the supply chain. Corrugated boxes used for cold chain applications must maintain structural integrity at refrigerated and frozen temperatures, where moisture exposure is significantly higher than ambient conditions.

• Wax-coated corrugated boxes resist moisture in refrigerated environments but are not recyclable
• Water-resistant coatings and treatments offer recyclable alternatives to wax
• Insulated corrugated shippers with EPS or reflective liners maintain temperature during transit
• Cold chain packaging must be validated through temperature monitoring during actual shipping conditions

Documentation and Traceability

Food safety regulations require comprehensive documentation of all packaging materials in the supply chain. Maintain certificates of compliance (COCs) from all packaging suppliers, retain material safety data sheets (MSDS) for inks, adhesives, and coatings, and implement lot tracking that connects specific packaging batches to the food products they contained. In the event of a recall, this documentation enables rapid identification of affected products and packaging.

Essential Documentation Checklist

• Certificate of Compliance (COC) from each packaging material supplier
• Material Safety Data Sheets (MSDS) for all inks, adhesives, and coatings used
• FDA food contact substance notifications or GRAS determinations for all materials
• Lot tracking records linking packaging batches to finished food products
• Supplier audit reports and food safety certifications (SQF, BRC, etc.)
• Internal inspection logs documenting packaging quality checks before use

Food-grade packaging compliance is not optional — it is a legal requirement and an ethical obligation. Understanding the regulations, choosing the right materials, preventing contamination, and maintaining proper documentation are the pillars of a safe and compliant food packaging program.