BUYER GUIDE / FOOD

Food-Contact Thermoforming Materials and Regulatory Compliance

Food-contact compliance is not a property of a material name but a conclusion based on resin grade, additives, processing conditions, intended contact (food type, temperature, duration) and the target market regulations. A tray project must define all of these before claiming suitability, and verify on the production-intent material and part.

Published and updated: 2026-08-25

Content author: Wenzhou Tonghou Plastic Products Co., Ltd.

04 / ENGINEERING NOTE

Compliance follows the full chain, not the resin name

Saying a tray is PP does not make it food-contact compliant; the grade, additives and processing all participate.

Confirm with the material supplier that the specific resin grade is approved for the intended food-contact application.
Check that any colour masterbatch, antifog agent or processing aid is also food-contact approved for the intended use.
Verify that forming, trimming and handling do not introduce contamination that would compromise the compliance chain.

05 / ENGINEERING NOTE

Intended use defines the requirement

The same material can be compliant for one food and not another, or at one temperature but not a higher one.

Define the food type: fatty, acidic, alcoholic, dry or aqueous, because migration limits differ.
Define the contact temperature and duration: hot-fill, microwave, frozen storage or ambient room contact.
The combination of material, food type, temperature and duration determines which regulation and which migration limits apply.

06 / ENGINEERING NOTE

Regulations are per market

A tray compliant for one market may not automatically satisfy another.

Identify the target market regulations: FDA in the US, EU 10/2011 and amendments in the EU, GB 9685 and related standards in China, or equivalent.
Check whether the regulation requires a compliance declaration, a test report, or both, and who is responsible for each.
Export projects should confirm the regulation of the destination market, not only the origin market.

Applications

Food and mooncake inner trays
Trays for direct or indirect food contact
Export food packaging targeting specific markets

Selection criteria

Resin grade and additive system confirmed for food contact
Processing conditions do not compromise compliance
Intended contact conditions defined: food type, temperature, duration
Target market regulations identified and addressed

Pre-production validation

Compliance is verified per project: confirm the resin and additive direction with the supplier, define the intended contact conditions, identify applicable regulations (such as FDA, EU 10/2011, GB 9685 or equivalent), and test on the production-intent formed part if required by the regulation or the buyer.

04 / DECISION MATRIX

Buyer decision table

Compliance element	What to confirm
Resin	Food-contact grade confirmed with supplier or certificate
Additives	Any colour, antifog or processing aids are food-contact approved
Processing	Forming, trimming and handling do not introduce contaminants
Intended use	Food type, contact temperature and duration defined
Regulation	Applicable standard identified per target market

05 / BUYER QUESTIONS

Common buyer questions

01Is every PP tray food-contact compliant?

No. The specific resin grade, additives, processing and intended contact conditions must be confirmed per project.

02What is a migration limit?

A regulation-set maximum for substances that can transfer from the packaging into food, tested under conditions representing the intended use.

03Does food-contact compliance expire?

Compliance is tied to the material, processing and intended use. Any change to resin, additives or process requires re-confirmation.

04Do I need a test report?

It depends on the regulation and the buyer. Some regulations allow supplier declarations; others require testing on the production-intent part.

06 / SOURCE BOUNDARY

Official references

These sources define terminology, testing or acceptance methods. Citing a standard does not claim Tonghou certification and does not replace project-specific validation.

U.S. FDA — Food Types & Conditions of Use for Food Contact Substances

Reference scope：Reference for defining the food type and actual temperature or storage condition; it does not certify a finished tray.