Food contact compliance for a custom printed box, bag, greaseproof sheet or cup is not a one-certificate exercise. The same item can require a different assessment when it holds hot, fatty or acidic food, when print moves closer to the contact surface or when the destination market changes. In the EU, Regulation (EC) No 1935/2004 provides the general framework and Regulation (EC) No 2023/2006 covers good manufacturing practice; material-specific and national rules may also apply. This checklist is not legal advice. It helps procurement, quality and supplier teams collect the right questions and evidence in one controlled file.
Write the intended-use scenario first
Compliance starts with foreseeable use, not the product name. Dry, aqueous, fatty or acidic food; hot filling, chilling, reheating, contact time and single-use operation can change the appropriate construction. State whether contact is direct or indirect and where the printed face sits after closing.
Instead of asking for a generic burger box, describe the normal worst case—for example, a fatty product packed at about 85 °C and held for roughly 30 minutes. The supplier can then relate its evidence and test scope to the actual order.
- Food type and fat/acid/moisture profile
- Filling and use temperature
- Contact time and storage
- Direct or indirect contact
- Destination country and instructions for use
Match evidence to the complete finished construction
Paper or board alone is not the finished pack. Coatings, barriers, adhesives, printing inks, varnishes and any films form one construction. The document set or linked specification should identify the product code, material build and print arrangement; do not transfer a generic statement from another grammage or an uncoated product.
Printing should remain on the non-food-contact side in normal use, set-off risk in the stack should be controlled, and converting should follow good manufacturing practice. Keep the sample, approved construction and production lots connected through traceable material codes.
Build a practical procurement evidence file
The same document name is not mandatory for every material and market. Ask the supplier to explain in writing which evidence applies to the relevant rules and intended use. Check scope, issue date, product reference, validity and any limits rather than filing documents by title alone.
Carry the same approved specification from quotation to goods receipt. Linking its revision to the purchase order reduces the risk that production differs from the sample used for approval.
- Product and material specification
- Applicable declaration or technical supporting evidence
- Test report and tested use conditions, where relevant
- Description of ink, adhesive and coating construction
- Lot and manufacturer traceability
- Commitment to notify material or process changes
Read beyond the test report cover
A laboratory report does not automatically cover the current order. Review the sample code, thickness or grammage, simulant, time, temperature, report date and limitations. Do not extrapolate a result to another substrate, hotter fill or longer contact without a justified assessment.
Special rules vary across paper and board, plastics, coatings and multi-material constructions. National provisions may apply where no specific EU measure exists. Confirm the destination market early and obtain competent compliance advice when scope is uncertain.
Verify the sample in realistic service
Document review does not replace physical trials, and a kitchen trial does not replace regulatory assessment. Pack the real food, close, wait, stack and transport it. Record odour or taste change, grease strike-through, delamination, bond opening, ink rub and any visible transfer.
Repeat the trial with the approved production construction under the hardest normal condition. Operational testing can expose a mistaken use assumption before purchase, even though it is not a substitute for laboratory analysis.
Treat changes as a new compliance checkpoint
Do not assume the old file remains valid when the paper supplier, coating, ink, adhesive, plant, printing process or intended use changes. Make advance change notification part of the purchasing terms and decide, by risk, whether documents, samples or testing must be renewed.
Record the product code, revision date, supplier, intended use, approver and review trigger. The evidence file then becomes a living control that connects each order to the correct construction, not a folder of unrelated certificates.
Verify the current official framework
The European Commission combines general safety and inertness principles with GMP, traceability and additional material-specific measures. Because rules evolve, check the consolidated text and destination-country requirements at the order date.