Food packaging regulations shape how brands and manufacturers choose materials that come into contact with food. In the United States, those requirements include federal FDA rules, along with state laws that may restrict certain chemicals or packaging uses. For food companies, the key question is how the material, intended food use, temperature, contact time, and supporting documentation fit together.
This guide covers the main rules and concepts food brands should understand when reviewing packaging materials for produce, seafood, frozen goods, and other food applications. It also explains how regulatory review fits into day-to-day purchasing decisions across the food industry.
How U.S. Food Packaging Regulations Work
The FDA regulates components of food contact materials under the Federal Food, Drug, and Cosmetic Act. Many packaging-related requirements appear in Title 21 of the Code of Federal Regulations, including rules for indirect food additives used in coatings, paper and paperboard, polymers, and other materials.
Compliance is tied to the specific substance and its intended conditions of use. A material that is suitable for one application may not automatically be suitable for another. Food type, temperature, length of contact, and the way the package is used can all affect the regulatory analysis. This is why the phrase “FDA approved” can be misleading when it’s used as a blanket statement about packaging materials. Food brands should look at the regulatory basis for the actual material and use case instead. Importers and brand owners also need to understand what information their suppliers rely on when they describe a package as suitable for food contact.
Food Contact Substances, Materials, and Articles
FDA terminology separates the individual substance, the material made with that substance, and the finished item. A food contact substance, or FCS, is a single substance intended for use as a component of materials used in manufacturing, packing, packaging, transporting, or holding food and is not intended to have a technical effect in the food. A food contact material can contain one or more food contact substances. A food contact article is the finished item, such as a carton, tray, film, bottle, or container.
These distinctions are useful because food safety reviews often focus on the substances that make up the finished package. Some substances can migrate into food under expected conditions of use. The potential for migration can depend on the food type, contact time, temperature, material composition, and other factors. That makes intended use an important part of evaluating food packaging materials. It also means a food-grade claim should be tied to a defined material and application rather than treated as a universal label.
When Does a Food Contact Substance Need FDA Authorization?
Food contact substances need an appropriate regulatory basis for their intended use. Depending on the substance and application, that basis may come from an existing FDA regulation, an effective Food Contact Notification, a Threshold of Regulation exemption, GRAS status, or a prior sanction.
Food Contact Notifications are especially important for newer food contact uses. An effective FCN is specific to the listed manufacturer or supplier, the substance, and the stated conditions of use. A similar material from another source doesn’t automatically receive the same authorization. Threshold of Regulation exemptions follow a different pathway and apply to specified uses that meet FDA criteria.
For food brands and manufacturers, the practical step is to match the regulatory basis to the package being purchased and the way it will be used. If a supplier changes a resin, additive, coating, or source, the supporting regulatory information may need to be reviewed again. That review is part of responsible food safety and procurement planning. Teams should also confirm that the authorization or exemption covers the expected food types, temperatures, and contact conditions.
Migration, Intended Use, and Compliance Documentation
Migration is the transfer of a substance from packaging into food. FDA safety reviews for food contact substances consider expected migration and the consumer exposure that could result. The amount that may migrate can vary with the material, food type, temperature, contact time, and manufacturing process.
Packaging buyers don’t need to treat every product as if it requires the same testing program. Instead, they should understand what information supports the intended use. Useful records may include the material specification, regulatory references, supplier statements, test data, and documentation describing the food types and use conditions covered. Some suppliers may also provide certificates or other quality records, depending on the material and purchasing requirements.
Keeping current records helps procurement teams compare packaging materials, respond to customer questions, prepare for audits, and trace changes in the supply chain. Documentation should match the actual package being purchased rather than a different grade, formulation, or use condition. For buyers, the goal is a clear paper trail that connects the material specification to the regulatory basis and the planned application.
PFAS, BPA, and State-Level Packaging Rules
Federal requirements are only part of the picture. States can add restrictions that affect food packaging sold within their borders, so brands with broad distribution may need to review more than one set of requirements.
PFAS restrictions are one current example. In February 2024, the FDA announced that PFAS-containing grease-proofing agents for paper food packaging were no longer being sold into the U.S. market. In January 2025, the FDA determined that 35 related Food Contact Notifications were no longer effective after those uses were abandoned. Other PFAS uses in food contact applications are evaluated separately.
BPA restrictions and California Proposition 65 can also affect packaging decisions in certain markets and applications. Requirements can change, and state rules may differ. Food brands should review the laws that apply where their products are sold and avoid assuming that compliance with federal regulations covers every state requirement. A national distribution plan may therefore require a broader review than a product sold in a single market.
What Food Brands Should Ask Packaging Suppliers
Supplier conversations should connect regulatory information to the real package and use case. A food brand may want to ask what materials and additives are used, what regulatory basis supports the intended food-contact use, and which food types and conditions are covered.
It’s also useful to ask what safety, migration, or quality information is available; how formulation or supplier changes are communicated; and what traceability records can be provided. Packaging should also be evaluated for the conditions it will face in the supply chain, including moisture, cold, stacking, handling, and storage.
These questions help buyers evaluate both food safety and performance. They also make it easier to compare suppliers using the same criteria instead of relying on broad terms such as “food grade” without knowing what that claim covers. For food industry purchasing teams, supplier documentation is most useful when it’s specific to the exact packaging material and intended application.
Packaging Needs for Produce, Seafood, and Frozen Foods
Food applications place different demands on packaging materials. Fresh produce may need airflow, moisture resistance, cooling access, and strength during refrigerated storage. Wet veg can move through a hydro-shower or ice-injector, which puts cartons in direct contact with water and ice. Seafood packaging may face similar moisture exposure during storage and transport.
Frozen foods add another set of operating conditions, including prolonged cold and condensation as products move through the supply chain. In each case, food-contact requirements should be considered alongside structural performance. A package can meet a regulatory requirement and still be a poor fit if it weakens, traps too much moisture, or doesn’t match the handling process.
For demanding cold-chain applications, moisture-resistant polypropylene corrugated cartons can provide a durable option when the material and intended use are appropriate for the food product. Packaging design should also account for the product’s size, packing method, pallet pattern, cooling process, and storage conditions.
Where Polypropylene Corrugated Packaging Fits
Polypropylene corrugated packaging is useful in applications where water, ice, refrigeration, and repeated handling can challenge traditional fiber-based cartons. SeaCa Plastic Packaging produces moisture-resistant polypropylene corrugated cartons for produce, seafood, and other food markets. Its cartons can be custom-made to fit customer and commodity needs, and the plastic cartons are recyclable.
SeaCa also no longer uses mineral content in its packaging because of its impact on product recyclability. That distinction supports the company’s focus on recyclable polypropylene packaging rather than mineral-filled blends like many imported cartons.
As with other packaging materials, food-contact suitability still depends on the specific material and intended application. Buyers should pair performance questions with the regulatory review described earlier. For SeaCa customers, that means considering carton design, moisture exposure, cooling methods, storage, transport, and the food-contact requirements that apply to the planned use.
Common Food Packaging Compliance Mistakes
Several avoidable mistakes can create problems for food brands. One is treating “food grade” as a universal FDA approval. Another is using a material outside the conditions covered by its regulatory basis. Outdated supplier records can also create gaps when a resin, additive, coating, or source changes.
Brands should also watch for state rules that apply in addition to federal regulations. Packaging claims deserve the same care. Food safety, recyclability, and sustainability statements should reflect the actual material and use rather than broad marketing language. Finally, packaging reviews should be revisited when products, suppliers, materials, or use conditions change. A regulatory decision made for one package does not automatically carry over to a new configuration.
Stay Current on Food Packaging Requirements
Food packaging regulations continue to develop as regulators review substances, states adopt new restrictions, and packaging materials change. Food brands and manufacturers can reduce risk by keeping supplier records current, matching regulatory support to intended use, and reviewing packaging changes before they reach production.
For produce, seafood, frozen goods, and other cold-chain applications, SeaCa Plastic Packaging can help customers evaluate polypropylene corrugated carton needs based on product size, moisture exposure, cooling, storage, and shipping conditions. Contact SeaCa to discuss packaging for your operation.
