Food contact paper is not selected only by barrier performance. Buyers also need a clear compliance file that matches the market, food type, contact conditions and converting process. This checklist is a practical starting point for paper cups, burger wrappers, lunch boxes, greaseproof liners, bakery packaging and other paper-based food packaging.
Important: this guide is for procurement and supplier communication. It is not legal advice. Final compliance should be confirmed with your regulatory team, importer, brand owner or qualified testing laboratory.
1. Define the Intended Use First
- Food type: dry, aqueous, acidic, alcoholic, fatty, hot-filled, frozen or microwave-heated.
- Contact condition: time, temperature, storage, reheating and whether the paper touches food directly.
- Structure: uncoated paper, greaseproof paper, water-based coated paper, PHA-coated paper, heat-sealable paper or laminated board.
- Function: grease resistance, water resistance, heat sealing, release, printing, forming or compostability/recyclability target.
2. FDA Checklist for the U.S. Market
For paper and paperboard used in U.S. food packaging, buyers normally review whether the ingredients, coatings and additives are covered by an applicable FDA food-contact pathway. A key starting point for paper and paperboard is 21 CFR Part 176, which covers indirect food additives for paper and paperboard components.
| Item to request | Why it matters |
|---|---|
| FDA food-contact statement or letter | Shows the supplier's regulatory basis for the intended U.S. food-contact use. |
| Material composition and coating type | Needed to confirm whether paper, coating, adhesive, sizing agent, ink or additive is relevant. |
| Food type and temperature limitations | FDA status is tied to intended use, not a universal “food grade” claim. |
| PFAS-free declaration and supporting test scope | Especially important for greaseproof paper, wrappers, bags and paperboard for oily foods. |
| Migration or extraction test reports when applicable | Useful for higher-risk structures such as coated paper, hot foods or fatty foods. |
FDA states that food contact substances are evaluated by expected dietary exposure and migration potential. FDA also announced that PFAS used as grease-proofing agents on paper and paperboard for food contact use are no longer being sold by manufacturers into the U.S. market, and in January 2025 it determined that 35 related food contact notifications are no longer effective based on abandonment of those uses. Buyers should therefore ask specifically whether a grease-resistant paper is made without intentionally added PFAS.
3. EU Checklist for Food Contact Paper
In the EU, all food contact materials must comply with EU food contact material rules, including the framework requirements of Regulation (EC) No 1935/2004. The European Commission notes that all FCMs must also be manufactured according to Good Manufacturing Practice under Regulation (EC) No 2023/2006, with specific EU rules for some materials and national rules for others.
| Item to request | Why it matters |
|---|---|
| EU Declaration of Compliance where applicable | Documents the regulatory basis and any use restrictions for the material. |
| GMP statement | Supports manufacturing control for food contact materials. |
| Traceability information | EU rules require traceability through the supply chain. |
| Migration or sensory test reports | Supports the core requirement that materials do not endanger health, change food composition or affect taste/smell under foreseeable use. |
| National market requirements | Paper and board may be affected by member-state rules where harmonized EU-specific measures are absent. |
4. Paper Packaging Document Pack
For most B2B purchasing projects, the buyer should build a document pack rather than rely on a single certificate. A practical pack includes:
- Product specification: grade, GSM, coating side, coating chemistry category, width, reel/sheet format and intended application.
- Food-contact statement: target market, food type, temperature and contact duration.
- PFAS declaration: whether intentionally added PFAS are used, plus the test method and sample scope if testing is provided.
- Migration/extraction reports: especially for fatty, hot, wet or long-contact foods.
- Heavy metals, sensory and microbiological checks when relevant to the buyer's risk profile.
- Traceability: batch number, production date, raw material lot and supplier contact.
5. What to Ask for Different Paper Types
| Material | Extra checks | Useful Bofmat resource |
|---|---|---|
| Greaseproof paper | PFAS-free declaration, grease resistance, oil-contact conditions, print-side separation | Food-grade greaseproof paper |
| Water-based barrier paper | Water/oil resistance, coating-side control, heat and wet-food testing | Water-based barrier coating paper |
| PHA-coated paper | Food-contact statement, biodegradation/compostability claims separated from food-contact compliance | PHA-coated paper |
| Heat-sealable paper | Seal temperature window, seal strength, blocking, migration under sealing conditions | Heat-sealable barrier paper guide |
6. Red Flags During Supplier Review
- A supplier says “food grade” but cannot define food type, temperature or contact time.
- PFAS-free is claimed for grease-resistant paper without a declaration or test scope.
- EU compliance is claimed without considering national paper-and-board requirements.
- Compostable or recyclable claims are used as a substitute for food-contact compliance.
- Test reports are for a different coating, different GSM, different application or expired sample batch.
Buyer Takeaway
For FDA and EU food contact paper, the safest procurement workflow is to define the real use case first, then request a document pack that matches that use case. For food packaging projects, Bofmat can help compare PFAS-free barrier paper, water-based coated burger wrappers, water-based cupstock, and PHA-coated food service board.
Share your target market, food type, filling temperature and converting process through our contact form. We can recommend sample structures for grease, water, heat-seal and food-contact document review.