Buyer guide · Compliance
When does packaging need food-contact migration review?
Any component intended to touch food directly requires the applicable specialist material, migration and compliance review for the actual food and conditions of use.
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Checklist
Compliance questions to assign and document
- Contact boundary
- Test method
- Document scope
- Use case
- Target quantity and SKU allocation
- Approval sample and decision owner
- Required date and Mainland China delivery point
- Change and repeat-order record
Evidence review
Four checks before approving claims or marks
Contact boundary
Confirm whether any component directly touches food and route direct-contact materials through the required specialist compliance review.
Test method
Name the method, conditioning, equipment, units and pass criteria; words such as strong or durable are not measurable specifications.
Document scope
Check certificate holder, site address, standard, product scope, issue body and validity instead of accepting a logo or screenshot.
Use case
Separate retail display, e-commerce delivery, gifting, storage and transport needs because they create different performance priorities.
Execution method
Four actions from RFQ to production
Define the destination and channel
Applicable content can differ by country, retailer, platform and product category.
Identify the responsible reviewer
Assign buyer legal, regulatory, brand or specialist approval rather than leaving it implicit.
Verify supplied evidence
Match reports, licences and permissions to the exact entity, product and validity period.
Archive the released content
Keep the approved wording, artwork version, evidence and decision date together.
FAQ
Questions buyers often ask
When does packaging need food-contact migration review?
Any component intended to touch food directly requires the applicable specialist material, migration and compliance review for the actual food and conditions of use.
What should be written in the specification?
At minimum, define Contact boundary, Test method, Document scope, Use case, then link quantity, sample, timing, inspection and the approved revision.
Is a physical sample needed?
A decision involving structure, material, colour, finish, assembly or use performance normally needs a physical sample matched to that question; a screen proof cannot approve everything.
Can the previous standard be reused for a repeat order?
Reuse a controlled standard only when files, material, structure, supply chain and use conditions remain unchanged. Record every change and decide whether resampling or reapproval is required.
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