“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.
Choosing between bins, basins and pans? The commercial food storage guide maps each format to its kitchen workflow.
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 |
The Audit-Ready Document File: What It Looks Like
When a customer auditor or customs officer asks for your food-contact documentation, the file should contain four documents, each doing a different job:
| Document | What it proves | What to check on it |
|---|---|---|
| Declaration of Compliance (DoC) | The material is legal for food contact under EU 10/2011 | Names the resin, the applicable regulation, and the use restrictions — a DoC without use restrictions is incomplete |
| Material data sheet | The actual resin grade behind the DoC | The resin grade must match the DoC, so the paper trail traces end to end |
| Migration test report | Transfer into food stays within legal limits | Test conditions must match your use case — hot fill, fatty food, repeated use |
| Change notification clause | You will hear about formulation changes | In the supply contract, not a verbal promise — a formulation change invalidates the old documents |
Use conditions that change your certification requirements
Migration is not a fixed number — the same material can pass in one use condition and fail in another. When you specify, specify the condition, not just “food grade”:
| Variable | Cold, dry, short contact | Hot, fatty, long contact |
|---|---|---|
| Temperature | Low migration | Hot filling multiplies migration versus cold storage |
| Food type | Dry goods extract least | Fatty and acidic foods extract more |
| Contact time | Trays used for minutes | Crates holding produce for days |
The practical consequence: a supplier certificate issued for cold, dry contact does not cover a hot-fill line, even though the resin is identical. Match the certificate to the process, or the certificate is decorative.
Five questions, five minutes, and they separate a compliant supply chain from a marketing claim with a certificate-shaped hole in it.
