식품 접촉 재료: 정의, 규정 및 규정 준수 확인 방법

Billions of cups, containers, and wrappers touch your food every day. Regulators call that entire category “food contact materials,” and the phrase carries legal weight most buyers only discover after something goes wrong. If you manufacture, import, or specify packaging, the practical question is not what the term means, but how you prove that a supplier’s product actually complies. This guide walks from the definition to the verification steps: the part most articles about food contact materials never reach.

What Are Food Contact Materials?

Food contact materials (FCMs) are all materials and articles intended to come into contact with food. That scope is deliberately wider than packaging: it includes food packaging and containers, but also cutlery and tableware, kitchen equipment, and even processing machinery and conveyor surfaces (European Commission, 2024). A paper coffee cup, a plastic lid, a soup bowl, a burger clamshell, a bakery box, the bag it is carried in, and the straw in your drink are all food contact articles.

Two practical implications follow from that scope. First, “food contact” is not a single material property; it is a compliance status that depends on the whole article: substrate, coating, ink, and even the sealing method. Second, most claims you see on packaging are self-declared. The wine-glass-and-fork symbol required in the EU (Regulation (EC) No 1935/2004, Annex II), the words “food contact safe,” and the label “FDA compliant” are statements made by the manufacturer, not certifications issued by a regulator.

Food Contact Materials by Type: Where Compliance Lives in Each

Each material family answers to a different compliance framework. The most important difference for buyers: plastics have a single EU-wide positive list; paper and paperboard do not. That gap matters for every paper-based takeaway item — cups, bowls, clamshells, bakery boxes, buckets, trays, and carry bags — because each is a coated, printed article whose compliance has to be assembled document by document rather than looked up on a list.

The lists and databases you can actually use

For plastics, the Union list in Annex I of Regulation (EU) No 10/2011 is searchable online, and the U.S. equivalent lives in FDA 21 CFR parts 174–178, which cover the substances permitted in food contact materials. For banned-substance screening, industry databases such as the FCMD list 142 substances prohibited in food packaging (ChemRadar, 2026). The EU updated its plastic positive list as recently as February 2026 (SGS, 2026).

One caution: being on a list is not the same as being compliant. Lists authorize substances; compliance is about how they behave in 당신의 article under 당신의 use conditions, which is why the next sections focus on conditions, documents, and verification.

Which Rules Apply to Your Market?

The framework you must satisfy depends on where the food is sold, not where the packaging is made.

Two dynamics are worth watching. First, EU regulation is tightening: the Commission revised the plastic positive list in early 2026 and is drafting formal guidance on the Declaration of Compliance under Articles 16 and 17 of 10/2011 (SGS, 2026; Food Packaging Forum, 2013). Second, paper-based packaging, the segment where harmonization is weakest, is under rising scrutiny, including PFAS restrictions on coatings. If you export to several markets, you will carry multiple sets of documents; you cannot substitute an EU dossier for the FDA one, and vice versa.

The Documents That Prove Compliance: What a DoC Should Contain

The Declaration of Compliance (DoC) is the backbone document. Under EU Regulation (EU) No 10/2011, Article 15, the DoC must be passed down the supply chain, from the producer to the importer or brand owner, and on to the food business, with the supporting documentation behind it held under Article 16 (Avery Dennison, 2024). That chain is exactly why importers and distributors get asked for it: it is how a food company proves its packaging to an auditor.

When a supplier hands you a DoC, check it against this list:

The last item is the one most often skipped, and the most dangerous. A DoC that does not state use conditions, or states conditions that do not match your application (hot-fill beverages, high-fat food, microwave use), does not cover you. BRCGS guidance documents real recalls caused exactly this way: packaging used outside the conditions it was designed for, for example when a carton’s plastic liner was swapped to cut costs (BRCGS, via IFSQN forum, 2022).

How to Verify a Packaging Supplier’s Food-Contact Claims

Once you know what documents exist, the verification itself is a five-step sequence. This is the part of the food contact materials story that almost nobody writes about, and the part importers and food businesses actually do.

Five verification steps

When each type of evidence stops being valid

Why Compliance Evidence Belongs in Your Sourcing Decision

For importers and distributors, this all reduces to a sourcing rule. You sit in the middle of the supply chain: the food brands you sell to are audited under schemes such as BRCGS, whose supplier-approval clauses require documented evidence from 그들의 packaging suppliers (BRCGS, via IFSQN forum, 2022). When they audit you, your upstream suppliers’ evidence chain is what you will be asked to show. And under EU rules, the DoC obligation travels down that same chain, which means the compliance risk does not stay with the factory; it travels to you.

So treat evidence completeness as a selection criterion with the same weight as price, MOQ, and lead time. When you request quotes, request documents in the same message. A supplier that ships a DoC and test report with the first sample saves you weeks; one that cannot produce either is a risk you are choosing to import.

Sourcing is cheaper when compliance is verified up front. The cost of rejecting a bad supplier at quotation stage is a few emails, while the cost of discovering it after arrival is a lost order, a failed audit, or a recall.

If you are sourcing food-contact paper packaging for the EU or US market, YoonPak’s food-contact-certified paper cups, bowls, takeaway containers, bakery boxes, trays, and paper bags ship with FDA and LFGB compliance documentation; the food-contact-certified paper packaging manufacturer page lists the full certification set.

참고 문헌

1. European Commission. “Food Contact Materials: Food Safety.” 2024. https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials_en
2. European Union. “Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food.” 2011. https://eur-lex.europa.eu/eli/reg/2011/10/oj/eng
3. Keller & Heckman. “The EU’s Plastics Regulation: What You Should Know.” 2022. https://www.khlaw.com/insights/eus-plastics-regulation-what-you-should-know
4. Measurlabs. “Testing of Paper and Board FCMs in the EU.” 2025. https://measurlabs.com/blog/testing-of-paper-and-board-fcms-in-the-eu/
5. SGS. “EU Updates Positive List for Food Contact Plastics.” 2026. https://www.sgs.com/en-us/news/2026/02/safeguards-02026-eu-updates-positive-list-for-food-contact-plastics
6. ChemRadar. “FCMD: Food Contact Materials Database.” 2026. https://www.chemradar.com/en/tools/fcmd
7. Avery Dennison. “EU Food Contact Materials: Compliance.” 2024. https://label.averydennison.com/eu/en/home/products/compliance/eu-food-contact.html
8. IFSQN Forum. “Food Grade Packaging Evidence” (BRCGS clauses cited in discussion). 2022. https://www.ifsqn.com/forum/index.php/topic/43764-food-grade-packaging-evidence/
9. Food Packaging Forum. “News from the EU Commission on Food Contact Materials” (DoC guidance under Articles 16/17). 2013. https://foodpackagingforum.org/news/news-from-the-eu-commission-on-food-contact-materials
10. Reddit r/ecommerce. “Looking for advice on food contact safety.” 2022. https://www.reddit.com/r/ecommerce/comments/vlf2nr/
11. YoonPak. “Paper Cup Manufacturer: Accreditations & QC.” 2026. https://www.yoonpak.com/paper-cup-manufacturer-3/
12. YoonPak. “Contact.” 2026. https://www.yoonpak.com/contact/
13. YoonPak. “Home.” 2026. https://www.yoonpak.com/