Interview: Regulatory Insights for Food Contacts Materials in the U.S.

We recently held a webinar on the most relevant chemical safety highlights for food contact materials for the U.S. market (consult the on-demand version). To help provide you with further insights, we interviewed our expert Judith Haber, UL's technical manager.

Question: Is a written declaration of compliance from manufacturers mandatory for plastic food contact materials in the United States?

Judy: In the United States, declaration of compliance is not mandatory. However, customers may ask for a letter of guaranty from manufacturers certifying compliance for the intended food-contact use of the articles they are purchasing.

Question: I’ve heard the terms indirect contact and incidental contact used when describing components of food contact materials. Are these the same, if not, what is the difference?

Judy: I also have heard people use these terms interchangeably. The Food and Drug Administration (FDA) actually defines these terms differently. Indirect food contact materials are those materials that might come in contact with food, such as the outside of a container. Incidental contact substance is defined as those that rarely come in contact with food and the contact is not purposeful or continuous. Food that contacts an extraneous part of a blender where contact is not expected is one example of incidental contact.

Question: Can you explain the “household” exemption?

Judy: Household exemption is a term I have also heard being used. However, there is no statutory or regulatory definition of household and the FDA has not codified a housewares exemption. The FDA puts the onus on the manufacturers of these products to ensure their items are suitable for use with food. A safety determination that includes migration data is strongly recommended by the FDA.

Please contact us to learn more about our portfolio of services for the food contact materials.