A Food Packaging Compliance Checklist for New Suppliers or Materials

Use this checklist whenever you're sourcing a new food-contact packaging product, switching suppliers, or shipping an existing product into a new market.

1. **Declaration of Compliance under EU Regulation 1935/2004** — confirms the material is safe for its intended food contact use and states any restrictions.

2. **Specific migration test results under EU Regulation 10/2011** — required for plastic food-contact materials, showing the product stays within migration limits for the food type and contact conditions it's used for.

3. **FDA 21 CFR Part 177 documentation** — needed for polymer-based food-contact articles sold into the United States, confirming the polymer complies with the applicable additive regulations.

4. **Japan Food Sanitation Act positive list check** — confirms the resin and additives used are on Japan's approved positive list if the product is sold there.

5. **California Proposition 65 review** — check whether the product needs a warning label for any listed chemicals, even if it already meets federal requirements.

6. **China Food Safety Law 2021 documentation** — relevant for materials manufactured in or imported into China, covering hygiene and safety requirements for food-related products.

7. **EU Directive 94/62/EC packaging waste compliance** — covers packaging composition limits and recovery/recycling obligations for packaging sold in the EU.

8. **ISO 22000:2018 certification (if applicable)** — shows the supplier has a food safety management system in place, useful when auditing new manufacturers.

9. **ISO 9001:2015 certification (if applicable)** — confirms the supplier has a documented quality management system, a useful baseline check alongside food-specific certifications.

None of these documents substitute for each other — a supplier's ISO 9001 certificate doesn't confirm migration testing, and a Prop 65 review doesn't confirm EU compliance. Food packaging compliance depends on matching the right documents to the destination market and the material type, not just collecting paperwork.

For buyers handling multiple suppliers and markets, keeping this checklist organized against each product line is often harder than the checklist itself. Food packaging compliance is easier to manage when you can see, at a glance, which documents you have and which are missing for each product and market.

If you want to see how Complyra keeps this kind of checklist organized for [food packaging and food-contact materials](/industries/food-packaging), it's worth a look.