FDA Restrictions for Food & Contact Paper Products

The Food and Drug Administration defines food contact substances as "any substance intended for use as a component of materials used in manufacturing, packing, transporting, or holding food if such use is not intended to have any technical effect in such food." Paper products such as cups, wrappers and plates are regulated by the FDA to ensure consumer safety.

GRAS

• The FDA maintains a list of food contact materials that are Generally Recognized As Safe. A substance is listed as safe based upon one of several guidelines approved by the FDA, "either through scientific procedures or, for a substance used in food before 1958, through experience based on common use in food." Substances found on this list are approved for use in food. Any substances not found can be submitted to the FDA for review and consideration.

Migration of Certain Elements

• All food packaging, including paper packaging, is subject to chemistry testing to determine if migration of certain elements occurs. As defined by SGS Consumer Testing Services, this means that unwanted elements could be transfered from the packages on to the food. These undesirable substances can become indirect food additives causing contamination of the product and, in some cases, illness in humans.

Fatty and Dry Foods

• Due to varying properties of food, paper products in contact with fatty foods are tested differently from those in contact with dry foods. Test methods are set forth by the Code of Federal Regulations. Fatty foods are subject to test method 21 CFR 176.170 and dry food is regulated under 21 CFR 176.180. The main difference between these methods is the list of approved substances for use in paper products. This is because some materials are more likely to migrate into fatty foods than into dry foods.