Food Packaging Compliance: What You Need to Know
If you supply, prepare, or sell food, the packaging it goes into isn’t just a presentation choice – it’s a legal one. UK food businesses have a duty to ensure that any container, film, or lid touching their product is safe, suitable, and properly documented. Yet “compliant packaging” is a phrase that gets used loosely, and it’s not always clear what it actually guarantees.
This guide breaks down what food packaging compliance really means in the UK: the certifications that matter, what food contact compliance covers, why migration testing exists, and the questions we’re asked most often by customers trying to get this right.
What “Food-Grade” Actually Means
“Food-grade” isn’t a single tickbox – it’s shorthand for a packaging item meeting the requirements to safely come into contact with food without contaminating it, tainting its flavour, or compromising its safety. In UK law, this sits under the Food Contact Materials (FCM) framework, which applies to anything intended to touch food: containers, films, lids, even the inks used in printing on packaging.
For a food business, using compliant packaging isn’t optional – it’s a legal requirement under food safety law, and Trading Standards and Environmental Health Officers can and do check it during inspections and audits.
BRCGS Certification: What It Covers (and What It Doesn’t)
BRCGS (formerly BRC) is one of the most widely recognised quality and safety standards in food packaging, and it’s a certification we hold across our product range. In short, it means the manufacturing process behind a product has been independently audited against strict criteria for hygiene, traceability, quality control, and consistency.
What BRCGS certification tells you:
- The factory’s processes have been independently audited, not just self-declared
- There’s a documented system for traceability – if something goes wrong, it can be traced back through the supply chain
- Hygiene and quality controls are checked regularly, not just at initial certification
What it doesn’t automatically tell you on its own:
- The specific material grade of an individual product (that’s a separate spec, not a certification)
- Whether a product has passed migration testing for your specific food type (more on this below)
- Country-of-origin or full supply chain transparency beyond the certified site
BRCGS is a strong baseline indicator of a well-run, audited manufacturing process – but it works alongside other documentation, not instead of it. A reputable supplier should be able to provide BRCGS certificates, technical data sheets, and migration test results as separate, available documents.
Food Contact Compliance: The Legal Layer
Food contact compliance refers to a packaging item meeting the requirements of UK food contact material regulations – primarily retained EU Regulation (EC) No 1935/2004 and its supporting measures, which set out the general principle that materials in contact with food must not transfer their constituents into the food in quantities that could endanger health, change its composition unacceptably, or alter its taste and smell.
For plastics specifically, Regulation (EU) No 10/2011 (the “Plastics Regulation”) goes further, setting out:
- Which substances can be used in food contact plastics
- Specific migration limits (SMLs) for individual substances
- Overall migration limits (OMLs) – the total amount of material allowed to transfer into food
- Declaration of Compliance (DoC) requirements – documentation a manufacturer or importer should be able to provide confirming the material meets the relevant rules
This is the layer that sits underneath certifications like BRCGS. A factory can be BRCGS certified and still need to demonstrate, product by product, that the actual plastic or board used is suitable for the food types and conditions (temperature, fat content, contact time) it will be used for.
Migration Testing: Why It Matters
Migration testing is the process of checking whether chemical substances from the packaging material transfer (“migrate”) into food, and if so, how much. It’s central to food contact compliance because it’s the actual evidence behind the legal limits.
Testing typically uses food simulants – substances that mimic the properties of real food (such as fatty, acidic, or aqueous foods) – under conditions that reflect realistic use, including:
- Contact time (a container used for a few hours behaves differently to one used for frozen storage over months)
- Temperature (oven-safe trays, freezer-grade containers, and ambient packaging all face very different conditions)
- Food type (fatty foods such as cheese or pâté tend to interact differently with plastics than watery or dry foods)
This is why a container’s stated use – freezer-grade, dual-ovenable, ambient – isn’t just a marketing description. It reflects the conditions the material has actually been tested and is suitable for. Using packaging outside its tested parameters (for example, putting a non-oven-safe container in an oven) isn’t just a performance risk, it can also affect compliance.
We’re a Distributor – Here’s Why That’s Worth Knowing
We’re upfront that SystemPAK is a distributor, not a manufacturer. We import and supply food packaging rather than producing it ourselves. In practice, this means our role is to source from manufacturing partners who meet the certifications and standards above, and to make sure the right documentation – BRCGS certificates, technical specifications, compliance declarations – is available to our customers when they need it.
If you ever need supporting documentation for an audit or due diligence file, our team can point you to the relevant certificates and specs for the products you’ve ordered.
Common Customer Questions
Are all SystemPAK products food-grade?
Yes. Our range is manufactured to FSA standards and our products are BRCGS certified, meaning the manufacturing processes behind them have been independently audited for food safety and quality.
What’s the difference between BRCGS certification and food contact compliance?
BRCGS certifies the manufacturing site and process. Food contact compliance is about the specific material meeting UK food contact regulations for the food type and conditions it’s used in. A product can, and should, have both.
Can I get compliance documentation for my own audits?
Yes, get in touch with our sales team and we can point you to the relevant certificates and technical data for the products you’ve purchased.
Does freezer-grade or oven-safe packaging need extra testing?
Materials rated for extreme conditions (such as freezer-grade down to -40°C, or dual-ovenable trays) are tested under those specific conditions, since migration behaviour changes with temperature. Always check a product’s stated temperature range and intended use before using it outside that spec.
Is recyclable packaging automatically food-grade compliant?
Not necessarily – recyclability and food contact compliance are separate properties. A material can be widely recyclable and still need to meet food contact migration requirements separately for its intended use.
Who regulates food packaging compliance in the UK?
Primarily the Food Standards Agency (FSA), alongside local authority Environmental Health and Trading Standards teams, who can inspect food businesses’ packaging and documentation as part of routine checks.
