What FDA Standards Need to Be Met by Plastic Take-Out Containers Exported to the U.S.?
author: Iris
2025-08-01
1. The U.S. FDA on Food Packaging Materials: In the End, What Are the Requirements?
First, Clear What the FDA CFR Title 21
The United States has a specialized agency called the FDA to manage food and drug safety, which is out of the regulations called “Code of Federal Regulations Title 21” (Title 21). Inside the 170th to 189th, it specializes in managing the safety of packaging materials used in food.
For example, the two most common sections:
- 177.1520 is for “polyethylene,” which is used to make ordinary plastic bags or flexible boxes;
- 177.1630 is for “polypropylene” (PP), which is the material we commonly use to make plastic food take-out containers.
If the material used in your food take-out containers is not covered by this regulation, you will not be allowed to sell them in the U.S.
Not All Plastics Can Be Used for Food
If you use PP or PET, it doesn't mean it's safe; it also depends on whether it has passed the FDA's test. As long as it is “direct contact with food” plastic, such as lunch boxes, packing boxes, microwave boxes, these must undergo the migration test (that is, to see whether there will be harmful ingredients to run into the food). Especially for Chinese take-out containers wholesale, you must find out whether the materials you use are compliant or not.
What Documents and Reports Should I Prepare Before Exporting?
When exporting to the US, customers may ask you: Do you have any test reports? What is the source of the material? Is it compliant? This is when you need to provide:
- Material Safety Data Sheet (MSDS)
- Food Migration Test Report (Migration Test)
- Manufacturer's Self-Declaration Letter of Guarantee (to ensure that your material is FDA compliant)
If you are using environmentally friendly materials such as PLA and pulp, it would be best to include an eco-safety statement to show that your material is not only environmentally friendly but also safe.
3. How Can You Make Your Food Containers Pass the FDA's Compliance Requirements?
Start at the Source and Choose the Right Material Supplier
Your first step in making plastic food take-out containers is to buy the right materials. Be sure to use food-grade materials that are FDA approved, such as PP, PET, PLA, and so on. It is not recommended to use recycled materials (especially recycled plastics) to make the food take-out containers in direct contact with food, because American customers are very sensitive to this; basically, they will say NO.
Find an Authoritative Laboratory to Do the Test
Don't guess by yourself, to export, you have to look for SGS, Intertek, TÜV, these internationally recognized third-party testing organizations, to do food contact material testing. They will help you do the heat migration test, grease migration test, etc., to ensure that your home-made Chinese take-out containers wholesale product complies. After getting the report, you can rest assured to take orders.
Prepare All the Compliance Documents, And the Customer Will Feel Relieved at a Glance
Customers exporting to the U.S. often need the following information:
- Letter of Compliance
- Material Safety Data Sheet (MSDS)
- Food Contact Declaration
These materials not only allow you to smooth customs clearance, but also enhance the customer's trust in your brand. Especially if you want to promote eco-friendly take-out containers, you need to use this set of information to make your customers feel at ease.
Where to Buy?
Huizhou Yangrui Printing & Packaging Co., Ltd., established in 2014, specializes in producing FDA-compliant plastic food packaging, such as PP lunch boxes, PET cold lunch boxes, and PLA eco-friendly boxes. Customization is available, and English documentation, MSDS, and FDA reports are available.
Contact Us:
Phone: +86-159 8949 1653
Email: sales@yrpak.com
Email: sales@yrpak.com
References
- U.S. Food and Drug Administration (FDA) – Food Contact Substance Notification.
- Code of Federal Regulations (CFR) Title 21 – Food and Drugs, Parts 174–186.
- China Certification & Inspection Group (CCIC) – FDA Testing and Certification Guidelines for Products Exported to the United States.
- SGS-CSTC Standards Technical Services – Food Contact Material Testing Services.
- "2024 China Food Packaging Industry Export Compliance White Paper" – Released by the China Business Industry Research Institute.
2. These Types of Plastic Take-Out Containers Have Stricter Compliance Requirements
Plastic Food Take-Out Containers That Can Be Heated
Americans especially love to use the microwave oven to heat up their meals, so if you make plastic food take-out containers and write “microwave safe” heat available, then the FDA will especially look at you to see if there will be any problems with this material at high temperatures. Are there chemicals that come out after heating? Is the material deformed? All these should be tested. Especially nowadays, many people like to use eco-friendly take-out containers, but the stability of eco-friendly materials is poor under high temperatures, so we have to pay more attention to them.
Lunch Boxes for Fatty Foods
Meat, cheese, and other oily foods, the material will be “soaked”, the FDA will require do “grease simulation test”. The FDA will require a “grease simulation test” to see if there are any bad things released from your material in an oily environment. If your main Chinese take-out containers wholesale, customers are doing fast food or cooked food, then this test must also be included.
Frozen Food or Long-Term Storage Containers
If you want to export frozen containers, the material must also pass the stability test under a freezing environment. They can't be brittle when frozen or have toxic ingredients released. Like PLA or pulp-based eco-friendly take-out containers, they may be easy to crack at low temperatures, and it is still recommended to use traditional plastics such as PP or PET.
4. Environmentally Friendly Materials, Such as PLA, Pulp, and Also to Comply with FDA Standards
Biodegradable ≠ Free from Testing
Many people think that PLA, pulp, and such biodegradable materials are natural and do not need to be tested. In fact, no matter what material you use, as long as it is “in direct contact with food”, you have to go through the FDA regulations. If you make eco-friendly take-out containers, you must also have the corresponding test report. Pulp lunch boxes with coatings, such as waterproof, oil-proof coating composition, should also be clearly stated.
Inspection Focus Has Changed: Not Only Check Whether There Is No Toxicity, But Also Check the Environmental By-Products
Now FDA not only checks whether there are plasticizers, heavy metals, but also checks whether the degradation of materials will produce microplastics, harmful by-products. For example, the pulp box bleaching, there are no heavy metal residues, which these customers may ask about. So export manufacturers must be prepared in advance to explain the source of materials and test reports.
Environmental Protection and Safety Should Be Grasped Together; Don't Be Biased
It is recommended that manufacturers provide two types of product lines, one is the traditional plastic food take-out containers, and the other is eco-friendly take-out containers, so that customers can choose according to the use of the scene. Some people want to be environmentally friendly, some people are afraid of high temperatures and deformation, and you will be able to meet.
Why Is Lightweight the Next Important Direction for the Plastic Take-Out Food Box?
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