France has clarified its framework for food packaging and food contact materials (FCMs), setting out detailed compliance, labelling and documentation requirements for manufacturers and distributors.
The guidance, issued by the Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF), outlines how operators must ensure food safety and prevent chemical migration from materials into food.
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The rules apply to all materials and objects intended to come into direct or indirect contact with food. This covers food packaging, kitchen utensils, tableware, infant feeding products, and equipment used in food production, processing, storage and transport.
Under EU food contact materials legislation, products must be inert in normal or foreseeable conditions of use. They must not endanger human health, alter the composition of food, or affect taste, smell or texture.
Scope of food packaging and FCMs
Food packaging and other food contact materials include bottles, trays, films, paper, boxes and containers, as well as spatulas, ladles, cutlery and industrial processing tools. Items for infants and young children, such as feeding bottles and teats, are also within scope.
Secondary packaging that may reasonably come into contact with food is included in the definition. By contrast, items such as refrigerator shelves, tables or spoon rests are not considered FCMs because direct contact with food is not normally expected, although hygiene standards still apply.
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By GlobalDataCompliant food packaging can be identified by the glass-and-fork symbol or wording such as “suitable for food contact”. The symbol may be absent where the intended use is obvious, for example on cookware or cutlery.
Other markings may indicate microwave suitability, dishwasher safety or specific temperature ranges. These labels define the conditions under which the manufacturer guarantees food packaging compliance.
Migration risk and improper use
The central principle of food packaging regulation is inertness. Materials must not transfer substances into food at levels that could pose a health risk or cause unacceptable changes in composition or organoleptic properties.
Migration can occur when unsuitable materials are exposed to heat, cold or certain food types, particularly fatty or acidic foods. The French authority highlights several improper practices, including cooking food in freezer bags or plastic wrap in ovens, using PVC tubes for shaping and heating food, and reusing single-use packaging for storage or cooking.
While reuse may align with circular economy objectives, single-use food packaging is assessed only for its intended purpose. Using it under different conditions can increase migration risk and compromise food safety.
The guidance also warns against heating food in multi-layer cartons containing aluminium, and against placing aluminium foil in direct contact with acidic foods at high temperatures due to potential aluminium migration.
Compliance documentation and labelling
Manufacturers of food packaging and other FCMs must provide a declaration of compliance confirming that products meet applicable legislation. For plastic materials, this declaration must follow Annex IV of Commission Regulation (EU) No 10/2011.
The declaration must specify the types of food the packaging can contact, along with time and temperature limits. It must be supported by technical documentation demonstrating compliance under reasonably foreseeable conditions of use.
Distributors and retailers must hold this documentation and ensure correct labelling. Claims on packaging must be accurate and not misleading.
The authority also addresses environmental terminology. Products described as “bio-based” or derived from renewable resources may still be plastics. Bio-based plastics are not necessarily biodegradable and can behave like conventional plastics in the environment.
Conversely, a fossil-based plastic may be biodegradable under defined conditions.
For operators in the food packaging supply chain, the clarification reinforces a consistent message: compliance depends on appropriate material selection, verified migration testing, clear documentation and accurate labelling.
Non-compliance may result in enforcement action or product withdrawal from the French market.
