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9 minUpdated 2026-03-10 · Reviewed by LT Plastics Engineering

Food Grade Packaging Requirements: What US Manufacturers Must Know (2026)

Everything US manufacturers need to know about food grade packaging requirements: the complete regulatory landscape, material standards, testing, documentation, and a practical compliance checklist.

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Quick answer: US food grade packaging must use FDA-compliant materials under 21 CFR 174–186, maintain migration-test and lot-traceability documentation, follow FSMA transportation rules when shipping, and meet any applicable state rules such as California's chemical disclosure requirements.

Part of our FDA & Food Safety Guide to Industrial Containers

Food Grade Packaging Requirements in the United States

The United States has one of the world's most comprehensive regulatory frameworks for food packaging. If you're a food manufacturer, processor, or distributor, your packaging and containers must comply with federal, state, and sometimes international standards.

This guide breaks down the complete regulatory landscape so you know exactly what's required — and how to prove compliance.

The Regulatory Landscape

Federal Regulations

Agency	Regulation	Scope
FDA	21 CFR 174-186	Food contact substances
FDA	21 CFR Part 1	FSMA rules
USDA/FSIS	9 CFR 416	Meat, poultry plants
EPA	40 CFR 180	Pesticide residues on packaging
DOT	49 CFR 173	Hazardous food shipping

State-Level Requirements

Several states have additional packaging requirements:

California Prop 65 — Warning requirements for chemicals in packaging

New York — Additional heavy metals restrictions in packaging

Washington — PFAS restrictions in food packaging (effective 2024)

Maine — Extended Producer Responsibility (EPR) for packaging

International Standards (for exporters)

EU Regulation 1935/2004 — Food contact materials (if exporting to EU)

CODEX Alimentarius — International food standards

Material Standards for Food Packaging

Approved Materials

For industrial containers, the primary approved materials are:

[HDPE](/resources/fda-approved-plastics-food-contact-materials-guide) — The standard for bulk bins, hoppers, and pallets

Stainless Steel 304/316 — For high-temperature or highly corrosive environments

Food-grade aluminum — For certain beverage and pharmaceutical applications

Material Disqualifiers

Materials that cannot be used for food-contact packaging:

Recycled plastics without FDA Letter of No Objection

Lead-containing materials (solder, paint, glazes)

Non-approved colorants or additives

Wood (for direct food contact in most applications) — see pallets guide

Testing Requirements

Migration Testing

Migration testing determines whether any substances transfer from the packaging material to food. Two types:

Test Type	What It Measures	When Required
Overall migration	Total mass transferred	All food contact materials
Specific migration	Individual substances	When specific additives are present

Testing Simulants

The FDA specifies food simulants that replicate different food types:

Simulant	Represents	Container
10% ethanol	Aqueous, acidic foods	Water, juice, vinegar
50% ethanol	Alcoholic beverages	Wine, spirits
Food oil	Fatty foods	Oils, dairy, meat
Tenax	Dry foods	Flour, sugar, spices

When Testing Is Required

New material formulations — Always

Changed suppliers — If resin source changes

New conditions of use — Higher temps, new food types

Routine verification — Periodic (annual recommended)

Documentation Requirements

Every food manufacturer must maintain a "compliance file" for their containers and packaging:

Required Documents

Material compliance certificates — From container manufacturer

21 CFR compliance statements — Specifying which regulations are met

Migration test results — If applicable to your conditions of use

Additive declarations — List of all additives with FDA approval references

Manufacturing quality records — From container supplier

Lot traceability — Container lot → resin lot → supplier

How Long to Keep Records

FDA requirement: 2 years minimum

Best practice: 5 years (matches statute of limitations)

Export (EU): 10 years for EU compliance

Common Violations and Penalties

Top 5 FDA Packaging Violations

Using non-compliant materials — Fine: $10,000-$500,000+, product recall

Missing documentation — Warning letter, potential injunction

Cross-contamination from containers — Product seizure, facility shutdown

Inadequate cleaning of reusable containers — FSMA violation

Using containers beyond rated conditions — Material compliance voided

Recent Enforcement Actions

The FDA has increased enforcement of food packaging regulations:

2023: 47% increase in food facility inspections

2024: New FSMA enforcement for sanitary transportation

2025: Proposed PFAS restrictions in food packaging

Compliance Checklist for Manufacturers

Materials

✅ All food-contact materials have FDA compliance certificates

✅ Only FDA-approved plastics used for containers

✅ Virgin resin verified (no recycled content for food contact)

✅ Additive declarations on file

Testing

✅ Migration testing completed for conditions of use

✅ Test results within FDA-specified limits

✅ Annual verification schedule in place

Documentation

✅ Compliance file organized and accessible

✅ Lot traceability system in place

✅ Cleaning and sanitization logs maintained

✅ Employee training records on file

Supplier Management

✅ Container supplier provides compliance documentation

✅ Supplier quality audits conducted (annually)

✅ Change notification agreements in place

How LT Plastics Simplifies Compliance

LT Plastics provides complete compliance documentation with every food-grade container order:

Material compliance certificates (21 CFR 177.1520)

FDA compliance statements

Additive declarations

Lot traceability documentation

Cleaning and sanitization protocols

Request a Free Compliance Consultation →

View FDA-Compliant Products →

Read the full FDA & Food Safety Guide →

FAQ

What federal agencies regulate food packaging besides the FDA?

USDA/FSIS regulates packaging for meat and poultry plants, the EPA regulates pesticide residues on packaging, and the DOT regulates packaging for hazardous food shipments under 49 CFR 173.

How long must food packaging compliance records be kept?

FDA requires a 2-year minimum; best practice is 5 years to align with the statute of limitations, and exporters to the EU should retain records for 10 years.

What triggers new migration testing for packaging materials?

New formulations, a change in resin supplier, new conditions of use such as higher temperatures, or routine annual verification all typically require new migration testing.

What are common FDA packaging violations?

The most frequent violations are using non-compliant materials, missing compliance documentation, cross-contamination from containers, inadequate cleaning of reusable containers, and using containers outside their rated conditions.

Sources

eCFR — 21 CFR Part 174 Indirect Food Additives General

FDA — Food Safety Modernization Act (FSMA)

USDA FSIS — Food Safety and Inspection Service

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