Food-contact compliance and sustainability claims are two different questions, and buyers who merge them make expensive mistakes. Compliance asks whether a paper bag may legally touch food in your market; a claim asks what you may print on it. Settle compliance first, then write the claim to fit the evidence you hold.
Compliance and claims are two different questions
Compliance answers a legal question about contact: does this paper, coating and ink transfer anything into food that endangers health or changes its composition? It is assessed per material and per market; the buyer's protection is a document trail — a declaration of compliance, migration data where required, and a grade declared suitable for the intended contact.
Claims answer a commercial question about wording: what may appear on the bag, the carton, the listing? That is consumer and advertising law. A bag can be suitable for food contact and still carry no claim, because the waste stream it lands in cannot support one.
Two words cause most of the trouble. Recyclable describes the waste stream where the item is actually collected — a claim about infrastructure, not about the paper. Compostable requires a defined composting environment and a standard that defines it. Neither is a synonym for "eco".
What each market actually asks for
In the European Union the framework is Regulation (EC) No 1935/2004 on food contact materials: materials must not transfer constituents in quantities that endanger health or change the food's composition. Where a bag carries a plastic layer, liner or window, buyers ask for Commission Regulation (EU) No 10/2011, the plastics measure, with its positive list and migration limits.
In North America the route runs through the FDA: 21 CFR Part 176 for paper and paperboard components, and 21 CFR Part 178 for adjuvants, production aids and sanitizers. What a supplier provides is a food-contact statement for the exact construction.
In Germany, and across the EU as guidance rather than law, the BfR Recommendations for paper and paperboard in food contact are often the specification a buyer names.
The references to cite in an enquiry:
Choosing by market
| Market | Regulatory basis | Applies to | Sustainability claim wording | Effective date |
|---|---|---|---|---|
| EU | Regulation (EC) No 1935/2004 (framework); (EU) No 10/2011 for a plastic layer or liner | All food contact materials on the EU market; the plastics measure for liners and coatings | Claim only what the rules and the actual collection stream support; name the environment and standard for compostability | Framework since 2004; plastics measure since 2011, as amended — check the consolidated text |
| North America | FDA 21 CFR Part 176 (paper and paperboard); Part 178 (adjuvants, production aids, sanitizers) | Paper and paperboard constructions and their processing aids | Recyclability depends on local collection; compostability needs a named standard and environment | Long-standing; 21 CFR is revised annually — check the current edition |
| General, multi-market | No single global rule — the destination's framework governs each shipment | Export and private-label runs shipped to several destinations from one specification | Use the narrowest wording that holds everywhere, or split artwork per market | Varies by destination; verify at the source before each print run |
The strictest destination sets the wording.
Wording a claim without overstepping
Let the evidence set the wording, not the other way round.
- Attach the condition to the word. "Recyclable where paper and board collection is available" is defensible; a bare "100% recyclable" is not. For compostability, name the environment and the standard the market recognises — EN 13432 in the EU, ASTM D6400 in the US.
- Match the claim to the construction. "Plastic-free" is wrong the moment a polyethylene liner or film window is in the bag.
- Keep the claim and the compliance statement apart. A sustainability claim on the artwork does not evidence food-contact suitability; a declaration of compliance is not marketing copy.
Avoid bare "eco", "green" and "biodegradable". Which material carries the claim is a separate decision — see the kraft paper bags, greaseproof paper bags and eco labels notes.
FAQ
Is a food-contact compliant bag automatically recyclable or compostable?
No. Compliance is about contact safety; recyclability depends on where the bag is collected, and compostability needs a defined environment and a standard.
Which regulation do I cite for a paper bag with a plastic liner?
In the EU, (EU) No 10/2011 for the plastic layer, with (EC) No 1935/2004 as the framework; in the US, 21 CFR Parts 176 and 178.
Can I print "compostable" if the bag is only industrially compostable?
Only with the environment named — for example, industrially compostable to a named standard.
Which documents do buyers ask for in practice?
A declaration of compliance and migration data where required, plus a statement that the grade suits the intended contact.
Browse the range
Start at eco paper bags for the whole line, then compare kraft paper bags for natural presentation and greaseproof paper bags for oily or moist content.