Lamination involves applying a plastic film and adhesive, which introduces the risk of substance migration. Consequently, the inner layer of food packaging typically utilizes food-grade varnish or water-based coatings to protect the printed surface, while finishes like matte film or soft-touch film are generally reserved for the outer layer or outer box. Adhesives used in post-processing also require attention; selecting an unsuitable glue for box gluing can compromise the structural integrity of the folded box. It is crucial to clearly define the intended use when discussing finishing effects so that the manufacturer can recommend the appropriate combination.
Food-contact ink is not synonymous with soy-based ink.
This step is easily overlooked. “Direct contact” refers to the inner surface of the packaging touching the food—such as cupcake liners, inner wrappers for cookies, or candy wrappers—whereas “indirect contact” implies a separating layer, such as an outer box containing individually wrapped candies. The requirements for each differ significantly, with much stricter constraints applied to direct-contact materials. When evaluating specifications, do not look at the box as a whole; focus specifically on which parts will touch the food. Many clients encounter confusion by failing to make this distinction.
When reviewing a test report, check three things: whether the tested sample matches the materials, inks, and processes of your actual order; whether the testing covers critical parameters like substance migration and heavy metals; and whether the report references the current version of the standard. Some clients hold reports from years ago that are no longer valid due to standard updates. In addition to test reports, a “Declaration of Compliance” provided by the supplier is a common document; it outlines applicable conditions and limitations. It is advisable to archive these documents by product line for future comparison when switching materials or suppliers.
Clients involved in food packaging often get confused by two terms: “food-grade” and “food-contact grade.” While they sound similar, they entail distinct requirements in the context of printing. For instance, a client might claim, “This is just an outer shipping carton; it doesn’t hold food directly,” yet the inner liner inside might be in direct contact with cookies. In such cases, the packaging must be treated as a food-contact material, and the regulatory requirements change immediately.
For exports, one must consider the requirements of the destination country in addition to domestic standards. The EU has a framework regulation (1935/2004) for food-contact materials, with specific regulations for plastics (10/2011); some clients also require compliance with German BfR recommendations. In the US, FDA regulations regarding paper and paperboard are the primary standard. A practical approach is to clarify the target market and applicable regulations with the client before placing an order, then have the manufacturer provide test reports based on those specific standards; this prevents discovering non-compliance—and the need for costly rework—only after production is complete.
While standard packaging printing focuses on aesthetics and structural strength, food packaging requires an additional assessment regarding potential food contamination. Fluorescent whitening agents in the paper, residual solvents and heavy metals in the inks, and adhesive layers used for lamination can all migrate into the food upon contact. Therefore, material selection for food packaging prioritizes safety compliance over visual appeal; aesthetic effects are considered only after safety requirements are met.
The inner layer of food packaging is typically not laminated.
Domestic production of paper and paperboard for food contact primarily adheres to the general safety requirements of GB 4806.1 and the specific provisions for paper and paperboard in GB 4806.8; the use of raw materials and additives must also comply with the list of permitted substances in GB 9685. Common testing parameters for paper products include sensory attributes, heavy metals, fluorescent substances, and microbiological indicators. Recycled pulp and virgin pulp are suitable for different applications; it is advisable to clarify material sources with the manufacturer at the time of ordering to avoid discovering material unsuitability only during inspection.
Regulatory compliance for food packaging is not a “one-and-done” matter; it remains valid only as long as the specifications remain unchanged. Any change in paper, ink suppliers, or printing facilities requires re-verification and updated documentation. A more efficient approach is to have suppliers provide comprehensive test reports and declarations of conformity for the entire product line upfront, creating an internal material dossier. This allows for simple verification with each subsequent order, which is far less burdensome than scrambling to locate reports later. Regulatory basis for food-contact paper and paperboard
Additional considerations for imported food packaging
Differences in requirements between food packaging printing and general packaging
How to interpret test reports and declarations of conformity
Soy-based ink is often synonymous with eco-friendliness and food safety, but it is merely one component of the ink formulation. Its suitability for food contact depends on whether the ink complies with the list of permitted substances under GB 9685 and whether the manufacturer can provide the corresponding compliance documentation. In food-related applications, the focus is on migration; low-migration inks and water-based inks are commonly used. Another detail to consider is “set-off” (or “back-trapping”)—where printed areas smudge onto the inner layer during winding or stacking—which also poses a migration risk; this requires particular attention with roll-fed materials.
Direct contact vs. indirect contact: first, distinguish between the two.
