LeapFood Grade Packaging — What It Means, Standards & How to Verify
What Does "Food Grade" Actually Mean?
Food grade packaging is a material or finished article that has been demonstrated safe for its intended food-contact use under an applicable regulation — it is a documented status, not a description of appearance or material type. Paper is not automatically food grade. Neither is plastic, bamboo or "natural" material. What makes packaging food grade is evidence: the specific substances used, the conditions of contact (temperature, duration, food type), and the compliance documentation that proves the two match.
This distinction matters commercially. A supplier that prints "food grade" on a carton without a Declaration of Compliance is offering an assertion, not a certification. If a shipment is inspected — or a retailer audits the packaging file — the assertion does not hold. This page sets out what the standards actually require, and what to ask for.
The Standards That Matter
US — FDA 21 CFR
Food-contact materials are regulated under Title 21 of the Code of Federal Regulations, Parts 170–189. Paper and paperboard components fall under 21 CFR 176.170; PET under 177.1630; olefins (PP, PE) under 177.1520. Compliance is substance-specific: the resins, additives, coatings and inks must each be permitted for the intended conditions of use.
EU — 1935/2004 + 10/2011
Regulation (EC) No 1935/2004 sets the general requirement that materials must not transfer constituents in quantities that endanger health or alter food. Plastics must additionally comply with (EU) No 10/2011: a positive list of permitted substances, an overall migration limit of 10 mg/dm², and specific migration limits per substance, supported by migration testing.
Compostability — EN 13432
EN 13432 is a separate claim from food grade: it certifies that a material biodegrades and disintegrates under industrial composting conditions. A product can be food grade without being compostable, and compostable without being food grade. Both claims require separate evidence.
How to Verify a Supplier's Claim
Four documents carry the weight. Ask for all of them before a first order — a supplier that cannot produce them is not food grade, whatever the website says.
| Document | What it proves | Watch for |
|---|---|---|
| Declaration of Compliance (DoC) | Material composition, permitted substances, migration test results against the named regulation | Must name the specific regulation and the intended conditions of use — a generic DoC covers nothing |
| FDA compliance letter or FCN | Specific resin/additive is permitted under 21 CFR for the stated use | For recycled (RPET) material, ask for the Letter of No Objection for the recycling process |
| Migration test report | Actual measured migration against the limits (10 mg/dm² overall; specific limits per substance) | Must come from an accredited laboratory, and must match the food type and temperature you will use |
| Certificate of Analysis (CoA) | Batch-level conformity of the material delivered | Batch-specific, not a generic marketing certificate |
One additional check applies to paper and molded pulp: ask for PFAS test results. PFAS were historically used as grease barriers in paper packaging; the US market has moved away from them, and the EU now sets specific limits. A PFAS-free declaration from an ISO 17025 laboratory is the only useful evidence.
Common Misconceptions
"Kraft paper is naturally food safe"
Kraft describes the pulping process, not the compliance status. Recycled kraft can carry mineral oil or printing-ink residue; virgin kraft still requires food-contact-compliant additives and coatings. Both need documentation.
"Compostable means food grade"
The two certifications are unrelated. EN 13432 tests disintegration and biodegradation; it says nothing about migration into food. A compostable tray can still fail food-contact requirements if its coatings are unsuitable.
"One certificate covers all products"
Compliance is product-specific and, for plastics, substance-specific. A DoC for a plain PE cup does not cover a PLA-coated cup, and a paper DoC does not cover the plastic lid it ships with.
"FDA approved"
The FDA does not "approve" food packaging as a category. It permits specific substances for specific uses. A supplier saying "FDA approved" without naming the regulation and the substance has told you nothing verifiable.
Food Grade Packaging — Frequently Asked Questions
Is food grade packaging the same as food safe packaging?
They are used interchangeably, but "food grade" usually refers to the material's regulatory status (permitted substances, compliance documentation), while "food safe" describes fitness for the specific use — the material plus the conditions of contact. A material can be food grade in general yet unsafe for a particular application if used outside its rated temperature or with an incompatible food type. Both concepts matter; the documentation must cover your actual use.
What documentation should I request from a packaging supplier?
Four core documents: a Declaration of Compliance naming the specific regulation and intended conditions of use; an FDA compliance letter or Food Contact Notification (for recycled material, a Letter of No Objection for the recycling process); an accredited migration test report matching your food type and temperature; and a batch Certificate of Analysis. For paper and molded pulp, add PFAS test results from an ISO 17025 laboratory.
What is the overall migration limit?
Under EU plastic regulation (EU) No 10/2011, the total migration of all substances from the packaging into food must not exceed 10 mg/dm² of contact surface. Individual substances also carry specific migration limits, some as low as 0.05 mg/kg. US FDA requirements work differently — they regulate the permitted substances and their conditions of use rather than setting a single overall limit — which is why a single test report cannot satisfy both regimes.
Does recycled packaging count as food grade?
Only when the recycling process has been evaluated for food contact. In the US, that means a Letter of No Objection from the FDA for the specific process; in the EU, an EFSA-evaluated process compliant with (EU) No 10/2011. Recycled content from an unevaluated stream cannot be used in direct food contact regardless of the feedstock quality. Not all RPET is food grade — the process, not the material name, determines it.
How do I verify PFAS-free claims?
Ask for a test report from an ISO 17025-accredited laboratory showing PFAS below the relevant threshold — the EU PPWR sets limits at 25 ppb for any individual PFAS and 250 ppb for the sum of non-polymeric PFAS from August 2026. A supplier declaration alone is weaker evidence than a laboratory result; for export markets where enforcement is tightening, the test report is the document that protects you.
What certifications do your products carry?
FDA food-contact documentation for US imports, EU 10/2011 compliance with a Declaration of Compliance for Europe, FSC chain-of-custody where certified paper is specified, EN 13432 and BPI for compostable formats, and ISO 17025-verified non-detect PFAS for paper and molded pulp. Certificates travel with each shipment. See our quality page for the full list and the QC process behind it.
Need compliance documentation for a tender?
Tell us the market and application — we will send the DoC, test reports and certificates that apply.
Request Documentation