Food-Contact Compliance Pack: Documents to Request From a Packaging Supplier
November 14, 2026
Before a packaging order ships, you should hold five documents: a declaration of compliance for the food-contact layer, a migration test report, a GMP statement, an ink and adhesive statement, and a specification sheet that names every layer and grammage. If a supplier cannot produce them for the exact material you are buying, the certificate you were shown belongs to a different product.
This guide explains what each document covers, what to check inside it, and the warning signs that a compliance pack has been assembled for show rather than for audit.
The five documents and what they prove
| Document | What it covers | What to check |
|---|---|---|
| Declaration of Compliance (DoC) | Food-contact compliance of the finished material | Names the material, the regulation, the test conditions and the date |
| Migration test report | Overall and specific migration against limits | Test conditions match your food type and temperature |
| GMP statement | Manufacturing under food-contact good practice | Covers the actual production site, not just the group |
| Ink and adhesive statement | Non-food-contact inks, low-migration where required | Says whether print is direct or reverse, and which ink series |
| Specification sheet | Layer order, grammage, coating, barrier values | Matches the sample and the purchase order exactly |
Regulation by market
In the United States, food-contact materials are regulated under the FDA's indirect food additive rules in 21 CFR Parts 175 to 178, with the concept of food contact substance notification for new substances. In the European Union, Framework Regulation (EC) 1935/2004 sets the general safety requirement, and Regulation (EU) 10/2011 covers plastic layers with a positive list, specific migration limits and the requirement for a DoC. China uses GB 4806 series standards. If you sell into several markets, the specification has to satisfy the strictest one you ship to.
Paper and board have their own national rules in some EU member states, and recycled fibre requires a risk assessment for mineral oil and other contaminants. A generic “food grade” stamp is not a substitute for these documents.
What to check inside a DoC
• The material description must match your structure, layer by layer, including coating and print.
• The regulation cited must be the one in force for your market, with the amendment date.
• The food contact conditions (fatty, aqueous, acidic, hot fill) must cover your product.
• The document must be signed and dated, and traceable to a batch or a production period.
• Any restriction or limitation must be stated, not buried in an annex.
Warning signs
A DoC that names only “paper” when the pack is a three-layer laminate is a red flag. So is a migration report tested in water when your product is oily, or a certificate with no date. Another common problem is a document issued for a sister factory while your order is produced elsewhere.
It is normal for some documents to be issued per material supplier rather than per converter. What matters is that the chain is complete and that the converter can show which material went into your order.
How we handle it
Our packaging is produced in FDA- and ISO-registered facilities, and certifications are held by our manufacturing partners. For each order we can provide the material specification, the DoC for the food-contact layer, and the ink and adhesive statements. Where a market requires testing against a specific standard, we will tell you what can be supplied and what has to be arranged locally, rather than implying a blanket approval.
Frequently asked questions
Does a DoC mean the packaging is approved in my country?
No. It is a declaration that the material meets a stated regulation. Approval to sell a packaged food is the responsibility of the food business and its importer, and some markets require additional national registration.
How often should documents be renewed?
Whenever the formulation, supplier or regulation changes, and at least annually. An undated or five-year-old DoC is worth questioning.
Are recycled paper packages food-safe?
Only with a risk assessment and a functional barrier. Recycled fibre can carry mineral oil and other contaminants, so it is not automatically suitable for direct contact.
Can we print a compliance claim on the pack?
We do not print approval claims on packaging, because regulators do not approve packaging as such. The correct route is to keep the compliance documents on file and let the buyer's regulatory team review them.
Tell us the market you ship to and the product contact conditions, and we will send the compliance pack that applies to that structure.
Related reading
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