Food-contact paper and films: what to check

“Is our packaging food-safe?” is unanswerable as asked, because the question belongs to neither a company nor a site. It belongs to one layer of the pack at a time. Start at the product and work outwards: whatever sits against the food is where the food-contact question lives, and the layers beyond it answer to different questions entirely.

Most lines have three. Primary packaging is the film, bag, liner or paper against the product. Secondary packaging is the case, tray or bundle grouping them. Transport packaging is the pallet wrap, strapping, corner boards and the pallet. On a normal pallet of sealed cases holding sealed containers, that outer layer never comes near the food.

To settle it, walk the line and mark every point where product is open and something touches it: a liner going into a crate of loose produce, interleaving between bare bakery items, a paper cover over a tote of rework. Foreseeable contact counts too. If cases are routinely opened and re-closed under the same material, that material is in scope.

The same material can be in order at one station and outside its declared use twenty metres away. Four variables move it. Heat: a hot fill, a warm product going straight into the pack, or something heated in the pack later. Fat, because fatty foods draw substances out of a material that a dry product leaves alone. Acidity. And time: minutes of contact is not months of shelf life.

So the answer is never the material on its own. It is the material, plus what the food is, how hot it is when they meet, and how long they sit together. Record them next to the specification, because a change to any one reopens a question you thought was closed: a new recipe, a hotter fill, a longer shelf life.

Paper is porous, absorbent and never only fibre. A finished paper article is fibre plus everything added to make it work: sizing and wet-strength chemistry, coatings and barriers, laminates, printing inks, and on a gummed tape the adhesive itself. It has to be assessed as supplied, not as bare kraft.

Where the fibre came from matters more here than anywhere else in the pack. Recovered paper carries residues from its previous life, mineral oils among the ones the industry watches most closely, so recycled grades are treated differently from virgin ones. Recycled content and food contact frequently pull in opposite directions; decide early which one this pack needs.

Paper and board also have no EU-wide specific measure of their own, unlike plastics, so paper questions get pointed at national frameworks. The German BfR recommendations for paper and board are the ones most often cited in Europe; the FDA's rules apply for the United States. Ask which framework a paper claim is written against before comparing two.

For film the first answer is usually that the question does not apply. Pallet stretch film wrapped around sealed cases is transport packaging: not intended to touch food, and not reasonably expected to. What it must do is hold the load, let a warm pallet lose its heat and vapour instead of sweating, and suit your customer's recycling stream.

Where a film genuinely does sit against food it is a plastic, and plastics are one of the few material groups with a harmonised EU measure of their own, Regulation (EU) No 10/2011, under the framework Regulation (EC) No 1935/2004. A compliant film article is declared for defined conditions, and the additives are the part to look at: slip agents, tackifiers, anti-fog, the ink on printed bundle wrap.

One trap catches buyers repeatedly. A grade belongs to an article, not to a brand or a building. Buying one compliant film for the station that touches product does not make the other films on site compliant, and a declaration written for a dry ambient pack does not cover the same pack filled hot.

Toreto holds FSC Chain of Custody certification, FSC-C227420, issued by SGS. It covers responsible fibre sourcing and traceability through the supply chain. It is not a food-contact certificate and is not presented as one: nothing about forests, quality systems or recycling answers a food-contact question, however useful those certificates are to hold.

What answers it is a declaration of compliance for the specific article and grade, written against the framework for that material and naming the conditions it covers. It is confirmed per article, not per company, which is why Toreto answers for the article you are buying and the conditions you give it, not with a badge. The documents themselves, and who carries the responsibility, are covered in “Food-use certified packaging: what to ask your supplier”.

Inks, coatings, laminates, adhesives and release agents are part of the finished article. A printed film and the same film unprinted are two different articles, as are a gummed paper tape and the kraft it is made from. Set-off is the version that catches people out: print on the outside of a reel can transfer onto the inside face when it is wound tight.

Recovered fibre and recycled polymer each need their own assessment rather than an assumption that recycled is a neutral swap. And anything added late is a change to the article, not a detail of it: a coating applied at converting, an ink change for a new design, a different adhesive on the same tape.

A declaration describes the article as it was when it was written. A change of base material, supplier or grade voids it, so agree at the start that you will be told when anything changes, rather than finding out from a delivery note. Ask for batch traceability too, so a query traces back to a production run rather than a year.

Then look at your own site, the part no supplier controls. Storage before use decides more than people expect: a compliant material kept next to solvents, under a leaking roof or in a bay where it takes up odour is no longer the material that was assessed. Give it the conditions you would give the packed product, and use stock in the order it arrived.