“Food grade” is the most over-used phrase in plastic product sales. It has a precise legal meaning — the material complies with a food-contact regulation — but it gets printed on products that were never tested. If you buy containers for food handling, export food-contact products, or answer customer audits, this is how the system actually works.
The two systems that matter
| System | Market | How it works |
|---|---|---|
| FDA 21 CFR | United States | Lists resins and additives permitted for food contact; compliance means using only listed substances within limits |
| EU 10/2011 | European Union | Sets migration limits — how much substance may transfer into food, tested under defined temperature/time/food-type conditions |
Other markets often reference one of these two (many Asian and Middle East buyers ask for “FDA” or “EU food grade” as shorthand). But approval under one system does not grant the other — exporting to both markets means documentation for both.
Migration: the concept behind everything
All food-contact regulation is about migration — tiny amounts of substance transferring from plastic into food. The variables:
- Temperature — hot filling multiplies migration versus cold storage
- Contact time — a crate holding produce for days differs from a tray used for minutes
- Food type — fatty and acidic foods extract more than dry goods
- Surface to volume ratio — small containers test worse than large ones
This is why a material can be food grade for cold dry contact but not for hot oily contact. When you specify, specify the use condition, not just “food grade”.
What to request from a supplier
- Declaration of Compliance (DoC) — for EU-bound product this is a legal document under 10/2011; it names the material, applicable regulation, and use restrictions.
- Material data sheet — the actual resin grade, so the DoC can be traced to it.
- Migration test reports — matched to your use conditions (hot fill? fatty food? repeated use?).
- Change notification clause — the supplier must tell you if the formulation changes, because a formulation change invalidates the old documents.
A supplier who cannot produce item 1 within a day is telling you something. Reputable manufacturers keep these documents current per product line — for example, our food-grade storage and washing guidance in the crate sanitising guide assumes certified material as the starting point.
Food grade vs food safe in practice
Certification covers the material. Practical food safety adds:
- Hygienic design — smooth surfaces, radius corners, no crevices (see our poultry equipment guide for wash-down requirements).
- Colour zoning — raw vs ready-to-eat separation; the colour-coded crate guide covers schemes.
- Wash regime — hot detergent washing on a schedule, with logs.
- Damage retirement — cracks hold residue no wash reaches; retire on crack.
Auditors check all four. The certificate gets you in the door; the operating discipline is what passes the audit.
Quick specification checklist
| Question | Why it matters |
|---|---|
| Which market: FDA, EU, or both? | Determines which documents you need |
| Hot fill or cold storage? | Migration testing condition |
| Fatty/acidic or dry food? | Food-type simulant used in tests |
| Single use or repeated washing? | Repeated-use testing is stricter |
| DoC on file, dated this year? | Regulation versions move |
Five questions, five minutes, and they separate a compliant supply chain from a marketing claim with a certificate-shaped hole in it.