Food Grade Packaging Certification Services | Food Contact Material Compliance Testing

Introduction

Every food product sold in India and international markets depends on two things being simultaneously true: the food inside must be safe, and the packaging it lives in must also be safe. Consumers and regulatory authorities alike assume both — but only one is typically the subject of active testing programmes. Food packaging safety, and the compliance testing that substantiates it, remains among the most underinvested areas of food quality assurance for manufacturers across the country.

Food grade packaging refers to packaging materials and articles that have been demonstrated, through testing and supporting documentation, to be suitable for direct or indirect contact with food — meaning they do not transfer harmful substances into food in quantities that pose a risk to human health, alter food composition unacceptably, or impair the taste, odour, or appearance of the product.

The risks associated with unsafe food contact packaging are specific and well-documented. Plastic packaging formulated with restricted plasticisers, printing inks containing lead or cadmium pigments, laminate adhesives with unreacted residual monomers, and recycled materials carrying contamination from previous use cycles can all transfer substances into food — invisibly, and without any detectable change in the product’s appearance or labelling. The consumer has no means of identifying the problem; regulatory authorities and buyers do, through documented compliance testing.

Compliance testing in support of food grade packaging claims serves four simultaneous functions. It protects consumers from chemical exposure through food contact materials. It protects manufacturers from the regulatory liability and reputational damage associated with non-compliant packaging. It satisfies the documentation requirements of organised retailers, international buyers, and export customs authorities. And it provides a defensible, audit-ready evidence base for any food grade claim the manufacturer or packaging supplier makes.

The Fair Labs provides NABL ISO/IEC 17025-accredited laboratory testing services that support food grade packaging compliance verification — including overall migration testing, specific migration testing, heavy metal testing, food contact material analysis, and physical and chemical packaging assessments. These test reports form the evidentiary backbone of a manufacturer’s or packaging supplier’s compliance documentation.

Important Distinction: The term “food grade packaging certification” is commonly used in industry to mean the process of demonstrating, through testing and documentation, that a packaging material meets applicable food contact safety standards. Food grade status for packaging is established through compliance testing against regulatory standards — it is not a single government-issued licence or stamp in most cases. The Fair Labs provides accredited laboratory testing and technical documentation support that manufacturers and suppliers use to substantiate food grade claims and respond to regulatory, buyer, and audit requirements. The Fair Labs does not issue statutory food safety approvals on behalf of government authorities.

What Is Food Grade Packaging?

Definition

Food grade packaging describes any packaging material or article — whether in direct or indirect contact with food — that satisfies the applicable safety criteria for food contact materials established under the relevant regulatory framework. In India, this framework is primarily set by the Food Safety and Standards Authority of India (FSSAI) through the Food Safety and Standards (Packaging) Regulations, 2018, which incorporate BIS standards as the technical benchmarks for specific material types.

A packaging material is food grade when it can be demonstrated, through laboratory testing and supporting documentation, that its constituents do not migrate into food in quantities that:

Endanger human health,
Bring about an unacceptable change in the composition of the food, or
Bring about a deterioration in the organoleptic characteristics (taste, odour, colour, texture) of the food.

This is the universal definition shared by the Indian, EU, and US regulatory frameworks, albeit implemented through different specific limits, approved substance lists, and testing protocols.

Food Contact Materials

The term food contact material (FCM) covers all materials and articles intended to come into contact with food, either directly or indirectly. This includes:

The primary packaging container (bottle, pouch, tray, can, wrapper)
Secondary packaging with food contact potential
Processing equipment surfaces, food handling equipment, and conveyors
Printing inks applied to the food contact side or capable of set-off migration to the food contact side
Coatings, adhesives, and lacquers used in multilayer and laminated packaging

The distinction between direct and indirect contact matters for testing scope. Direct food contact materials are those that physically touch the food during normal use. Indirect contact materials — such as the outer layer of a laminate where migration through the structure is the pathway — are still subject to food safety assessment, though the migration distance and material barrier properties affect how testing is scoped.

Why Testing Is Required

Food grade status cannot be determined by visual inspection, polymer type alone, or supplier declaration. Packaging materials of nominally similar polymer type can differ substantially in additive package composition, pigment content, recycled material incorporation, and processing history — all of which affect migration behaviour. The only reliable method of confirming food grade status is instrument-based laboratory analysis of the actual material or article under conditions that reflect its intended food contact use.

Why Food Grade Packaging Compliance Matters

Consumer Safety

The primary reason food contact packaging is regulated is consumer protection. Substances that migrate from packaging into food — residual monomers, plasticisers, stabilisers, heavy metals from pigments, and solvent residues from inks — can pose health risks ranging from acute gastrointestinal effects to chronic toxicity and carcinogenicity at sustained low-level exposure. Food packaging reaches every household, every day, and is consumed by vulnerable groups including infants, children, pregnant women, and elderly individuals with reduced physiological tolerance. The regulatory system is designed to manage this exposure at a population level.

Food Contamination Prevention

Packaging-derived contamination shares a counterintuitive characteristic with microbiological contamination: it is not detectable by the food manufacturer or consumer without testing. A food product manufactured, processed, and stored to the highest hygiene standards can still be rendered non-compliant by packaging that fails migration testing — because contamination from food contact materials is treated as food contamination under FSSAI and international food safety law. This is why packaging compliance is a food safety issue, not merely a materials procurement question.

Regulatory Compliance

Food businesses in India that place food in non-compliant packaging are exposed to regulatory action under the Food Safety and Standards Act, 2006 and its associated regulations — including product seizure, prohibition orders, and penalties. For packaging manufacturers and converters, supplying non-compliant food contact packaging exposes their own business to liability. Documenting compliance through laboratory testing is both a legal obligation and a commercial risk-management measure.

Buyer and Retailer Requirements

Major food retailers, quick-service restaurant chains, and food brand commissioners across the organised sector now require active food contact material compliance documentation from their packaging suppliers as a standard condition of vendor approval. A supplier that cannot produce current test reports — meaning reports for the current material formulation, not a generic legacy document — is increasingly likely to fail vendor qualification, even if their packaging has been used without complaint for years.

Export Requirements

Export markets impose their own food contact material compliance requirements, which are not automatically satisfied by FSSAI/BIS compliance in all cases. The EU, in particular, requires not only that materials meet the Overall Migration Limit under EU Regulation (EU) No. 10/2011 but that manufacturers maintain a documented compliance system including Declarations of Compliance (DoC) and supporting test data for materials throughout the supply chain. US FDA regulations impose their own requirements through 21 CFR. Exporters who cannot produce market-specific compliance documentation face detention, destruction, or return of shipments at their own cost.

Product Quality Assurance

Even where migration levels fall within regulatory limits, the presence of solvent residues, ink-related compounds, or polymer degradation products in packaging can impair the sensory quality of the food — altering flavour, aroma, or appearance in ways that damage consumer satisfaction and repeat purchase. Organoleptic testing as part of a food grade assessment identifies these quality-level impacts before they reach the market.

Testing Required to Demonstrate Food Grade Compliance

Food grade packaging compliance is not established by a single test. The appropriate testing programme depends on the packaging material type, its food contact application, and the markets in which it will be sold or used. The table below summarises the core test types and their purpose.

Test Type	Purpose	Importance	Applicable Packaging
Overall Migration Testing	Measures total non-volatile substances migrating from packaging into food simulant — assessed against the Overall Migration Limit (OML)	Establishes baseline food contact inertness; required under FSSAI, BIS and EU frameworks	All plastic food contact materials
Specific Migration Testing	Quantifies individually named substances (monomers, additives, degradation products) against their own specific migration limits (SMLs)	Required for regulated substances present in the packaging formulation; provides substance-level safety evidence	Plastic packaging, laminates, coatings
Heavy Metal Testing	Detects lead, cadmium, mercury, hexavalent chromium, arsenic, antimony and other restricted metals in packaging material or simulant	Protects against toxicological risk from metallic pigments, stabilisers and recycled content; required for CONEG, EU and FSSAI compliance	All packaging types — plastic, paper, printed, metal, glass
Food Contact Material Testing	Comprehensive assessment of a packaging material’s chemical composition and safety profile for its intended food contact use	Provides a complete compliance picture, particularly for complex materials and new packaging formats	All food contact materials
Packaging Material Testing	Physical, mechanical and barrier property testing of packaging structure	Confirms that packaging maintains product integrity and does not compromise food through structural failure	All packaging types
Organoleptic Testing	Assesses taste, odour and sensory impact of packaging on food or food simulant	Identifies quality impairment from packaging-derived substances below regulatory limits; important for premium food products	Food packaging with printed, adhesive, or complex laminate structures
Chemical Testing	Targeted analysis for specific regulated chemical substances including solvents, monomers, and residual processing chemicals	Confirms absence or compliant levels of specific chemical contaminants not covered under migration testing	Flexible packaging, printed packaging, adhesive laminates
Physical Testing	Tensile strength, seal strength, burst testing, drop test, barrier testing	Verifies packaging structural performance under transit and storage conditions	All packaging formats
Declaration of Compliance Support	Technical review and documentation support for preparing DoC aligned to EU and other market requirements	Required for EU supply chains; essential export compliance document for packaging sold into EU	All packaging types sold into EU market supply chains

Callout: The appropriate scope of food grade compliance testing is determined by the packaging material type, the food category it will contact, and the regulatory framework(s) of the destination market. The Fair Labs recommends that manufacturers and packaging suppliers define their testing scope with reference to all markets in which their packaging will be used — not only the primary domestic market.

Packaging Materials We Test

The Fair Labs accepts food grade compliance testing submissions across the full range of food contact packaging formats in current commercial use:

Plastic Packaging (general)
PET Bottles
HDPE Containers
LDPE Packaging
Polypropylene Packaging
Flexible Packaging
Laminated Packaging
Multilayer Packaging
Food Containers (rigid and semi-rigid)
Beverage Bottles
Cups
Trays
Paper Packaging
Paperboard Packaging
Aluminium Packaging
Metal Packaging
Glass Packaging

Testing protocols, simulant selection, and sample preparation methods are matched to the specific material type, layer structure, and intended food category for each submission.

Applicable Regulations & Standards

FSSAI Packaging Regulations

The Food Safety and Standards (Packaging) Regulations, 2018 govern the packaging of food products in India. These regulations require that packaging materials used for food must be suitable for their intended use, must not contaminate the food they contain, and must meet the applicable Indian standards referenced in the regulations. FSSAI’s regulatory framework applies to all food businesses manufacturing, storing, or distributing food products in India and carries enforcement authority under the Food Safety and Standards Act, 2006.

BIS Standards for Food Contact Materials

The Bureau of Indian Standards issues the technical specifications that FSSAI’s regulations implement for specific packaging material types. The most relevant IS standards for food contact material compliance testing include:

IS 9845 — Specifies overall migration testing requirements for plastics intended for food contact use, including approved simulants, test conditions, and the Overall Migration Limit.
IS 10146 — Requirements for polyethylene (PE) as a food contact material, including permissible additive lists and migration criteria.
IS 10142 — Requirements for polyvinyl chloride (PVC) in contact with foodstuffs.
IS 10910 — Requirements for polypropylene (PP) used as a food contact material.
IS 12252 — General requirements for plastics materials and articles intended for food contact, addressing restricted substances and migration parameters across the polymer category.

Additional IS standards address paper, paperboard, aluminium, and glass packaging used in food contact applications.

EU Regulation (EC) No. 1935/2004

This Framework Regulation establishes the general food contact material safety principle applicable across all material types in the European Union. It requires that food contact materials do not transfer their constituents to food in quantities that endanger human health, change food composition unacceptably, or cause organoleptic deterioration. All food contact materials placed on the EU market, regardless of type, must comply with this framework.

EU Regulation (EU) No. 10/2011

This regulation governs plastic food contact materials specifically within the EU, establishing the Union list of authorised substances, the Overall Migration Limit of 10 mg/dm², specific migration limits for individual substances, and the requirement for Declarations of Compliance (DoC) to be maintained at each step of the supply chain. For any food business or packaging supplier exporting into or operating within the EU single market, compliance with this regulation and the maintenance of supporting DoC documentation is mandatory.

US FDA Food Contact Material Regulations

In the United States, food contact materials are regulated under 21 CFR Parts 174–186, which govern indirect food additives and food contact substances. The FDA’s framework establishes permitted substances for specific food contact uses and migration thresholds. Compliance is managed through a combination of premarket approval, food contact notifications (FCNs), and threshold of regulation exemptions.

Domestic vs. Export Compliance: Why Both Matter

Callout — Multi-Market Compliance Gap: One of the most common errors in food packaging compliance planning is assuming that FSSAI and BIS compliance automatically satisfies EU or US FDA requirements. It does not. Specific migration limits, approved substance lists, and the requirement for formal Declaration of Compliance documentation differ between frameworks. A PET bottle compliant under IS 9845 for domestic use may still require specific antimony migration testing, EU-compliant DoC preparation, and Regulation (EU) No. 10/2011 assessment before it can be used by a food exporter supplying the EU market. Manufacturers supplying both domestic and export markets should build their compliance testing programme around the most stringent applicable standard and should confirm multi-market compliance before packaging is committed to production.

Our Food Grade Packaging Compliance Process

The Fair Labs follows a structured, documented workflow for food grade compliance testing, from initial sample submission to final test report.

Sample Submission — Packaging samples are submitted by the manufacturer or packaging supplier, accompanied by information on the material type, composition (where available), intended food contact application, food category, and the regulatory markets for which compliance is required. Samples may be submitted via pan-India courier or at any designated collection point.
Packaging Review — Our technical team evaluates the submitted materials and client information to understand the packaging structure, layer composition (particularly for multilayer and laminated packaging), the presence of inks, coatings, and adhesives, and the intended conditions of food contact (ambient, refrigerated, hot-fill, microwave, etc.).
Selection of Required Tests — Based on the packaging review and the applicable regulatory framework(s), the appropriate testing scope is determined — typically combining overall migration testing, heavy metal testing, and any additional specific migration or chemical tests indicated by the material’s formulation or the target market’s requirements.
Laboratory Testing — Testing is performed under the selected conditions using validated, accredited methods. Food simulants are selected to match the intended food category. Test temperatures and durations reflect the packaging’s actual conditions of use. All testing is conducted under NABL ISO/IEC 17025 accreditation.
Compliance Assessment — Results are evaluated against the applicable regulatory limits for each target market — FSSAI/BIS for domestic compliance, EU Regulation (EU) No. 10/2011 for EU, and US FDA for US market compliance. Borderline findings are flagged with technical commentary.
Documentation Review — Where the client requires support for Declaration of Compliance preparation (particularly for EU supply chains), our technical team reviews available test data, material information, and substance declarations to assist in structuring compliant documentation.
Final Test Report — A formal NABL-accredited test report is issued, documenting sample details, test methodology, results, and compliance assessment against applicable limits. Reports are formatted to serve as primary compliance evidence for regulatory submissions, buyer documentation, export clearance, and internal quality assurance records.

Industries We Serve

Food Manufacturers
Beverage Companies
Dairy Industry
Ready-to-Eat Food Manufacturers
Snack Manufacturers
Bakery Industry
Nutraceutical Manufacturers
Pharmaceutical Industry
Cosmetic Industry
Packaging Manufacturers

Why Choose The Fair Labs

NABL ISO/IEC 17025 Accredited Laboratory — All food grade compliance testing is performed under internationally recognised accreditation, providing test reports accepted by regulators, retailers, buyers, and export authorities.
Food Contact Material Expertise — A specialist technical team experienced in FCM testing, simulant selection, multi-market compliance assessment, and Declaration of Compliance support — not a general-purpose testing operation applying food contact testing as an afterthought.
Advanced Testing Infrastructure — ICP-MS, ICP-OES, GC-MS, LC-MS/MS, and gravimetric migration testing capability, covering the full range of analytes required for comprehensive food grade compliance verification.
BIS, FSSAI, EU & US FDA Compliant Methods — Testing designed around the actual regulatory methods prescribed for each framework, not adapted generic protocols, ensuring results are directly comparable to applicable limits.
Experienced Scientists — Analysts and regulatory specialists with practical experience interpreting food contact material compliance requirements across domestic and multiple export markets.
Fast Turnaround Time — Defined turnaround commitments structured around production timelines, export schedules, and buyer qualification deadlines.
Reliable Reports — Audit-ready, NABL-accredited test reports formatted to serve as compliance evidence across multiple use cases simultaneously — regulatory, commercial, and export documentation.
Technical Consultation — Guidance on test scope selection, simulant choice, multi-market compliance strategy, and interpretation of results — particularly valuable for new packaging formats, new export markets, or reformulated packaging structures.
Pan-India Sample Acceptance — Logistics support for sample collection and submission from manufacturing facilities, warehouses, and ports nationwide.

Related Packaging Testing Services

Frequently Asked Questions

1. What is food grade packaging? Food grade packaging refers to packaging materials and articles that have been demonstrated — through laboratory testing and supporting documentation — to be suitable for direct or indirect food contact. A food grade material must not transfer substances to food in quantities that endanger human health, alter food composition unacceptably, or impair organoleptic characteristics. Food grade status is established through compliance testing against applicable standards, not by the polymer type alone.

2. How can packaging be demonstrated to be food grade? Food grade compliance is demonstrated through laboratory testing — primarily overall migration testing to confirm the material does not exceed the Overall Migration Limit (OML), heavy metal testing to confirm the absence of restricted toxic metals, and specific migration testing for individually regulated substances present in the formulation. Supporting documentation, including test reports from an accredited laboratory and, where applicable, Declarations of Compliance, provides the evidence base that regulators, buyers, and auditors expect. The Fair Labs provides accredited testing and documentation support for this process. The Fair Labs does not issue statutory government approvals on behalf of regulatory authorities.

3. Is food grade packaging testing mandatory? Food contact packaging placed on the Indian market must comply with the Food Safety and Standards (Packaging) Regulations, 2018 and applicable BIS standards, making compliance testing an implicit legal obligation for food businesses using such packaging. For export markets — particularly the EU — the requirement is explicit: Regulation (EU) No. 10/2011 requires compliance testing data to be maintained at every step of the food contact material supply chain. Many large buyers and retailers impose testing requirements independently of regulatory mandates.

4. Which tests are required for food grade packaging? The core testing requirements are overall migration testing (for plastics), heavy metal testing (for all packaging types, particularly printed and coloured materials), and specific migration testing for any regulated substances present in the formulation. Additional tests — organoleptic assessment, chemical analysis for solvents or residual monomers, physical barrier testing — may be required depending on the packaging type, food category, and target market. The Fair Labs recommends defining the test scope against the most stringent applicable standard for all markets the packaging will be used in.

5. What is food contact material testing? Food contact material (FCM) testing is the collective term for the laboratory assessments used to evaluate the safety and regulatory compliance of packaging and other materials intended for food contact use. It encompasses migration testing (overall and specific), heavy metal analysis, organoleptic assessment, chemical analysis, and physical testing — the combination of which provides a complete picture of whether a material is suitable for its intended food contact application.

6. What is the difference between overall and specific migration testing? Overall migration testing measures the total combined mass of all non-volatile substances migrating from a packaging material into food simulant, expressed as a single aggregate figure assessed against the Overall Migration Limit (typically 10 mg/dm²). Specific migration testing quantifies an individually named substance — a particular monomer, plasticiser, or additive — against that substance’s own specific migration limit (SML), which is set based on its toxicological profile. Both tests are frequently required together for complete compliance, particularly for plastic food contact materials entering the EU market.

7. Which packaging materials require food grade compliance testing? Any material intended for direct or indirect food contact requires assessment against applicable food grade standards — including plastic bottles and containers, flexible packaging and laminates, metal cans, aluminium foil, glass containers, paper and paperboard packaging, and printed packaging of all types. The specific test scope varies by material type and food category, but no major food contact packaging format is exempt from compliance obligations.

8. Is NABL laboratory testing accepted for regulatory and buyer compliance purposes? Yes. NABL ISO/IEC 17025 accreditation is the recognised standard for laboratory technical competence in India, and NABL-accredited test reports are accepted by FSSAI, BIS, export customs authorities, and international buyers and retailers as primary evidence of compliance. Accredited laboratory reports from The Fair Labs are formatted to serve directly as compliance documentation across regulatory, commercial, and audit contexts.

9. How long does food grade packaging testing take? Turnaround depends on the test scope. Overall migration testing protocols involve defined simulant contact periods (typically 10 days at 40°C under standard conditions) before gravimetric analysis can be completed. Heavy metal and chemical analyses are typically faster. The Fair Labs confirms expected turnaround for each specific test combination at the time of sample submission, structured around the client’s production and commercial timeline requirements.

10. Can food grade packaging compliance testing support export requirements? Yes. Testing against EU Regulation (EU) No. 10/2011 parameters and CONEG heavy metal limits — combined with supporting Declaration of Compliance preparation — provides the documentation structure that EU and US food contact material supply chains require. Where specific destination market compliance is needed, The Fair Labs structures the test programme and reporting to address those requirements directly, rather than defaulting to domestic-only testing that may leave export compliance gaps.

Get Your Packaging Assessed for Food Grade Compliance

Demonstrating that your packaging is food grade is no longer a documentation exercise completed once and filed away. Buyers, regulators, and export authorities expect current, accredited test data reflecting the actual packaging material in commercial use today. As formulations change, suppliers change, and recycled content increases across the packaging industry, the test data that underpinned a compliance claim from three years ago may no longer be representative.

The Fair Labs helps manufacturers, packaging suppliers, and exporters build and maintain the evidence base that food grade packaging claims require — through accredited testing, technical consultation, and compliance documentation aligned to domestic and international standards.

Request a Testing Quote · Submit Packaging Samples · Book Food Grade Packaging Testing · Speak with a Packaging Compliance Expert

Contact The Fair Labs today to discuss your food grade packaging compliance requirements and receive a structured testing proposal matched to your packaging format, food category, and target market.