Food contact materials
EU Food Contact Molded Fiber Packaging: Requirements and Documentation
Food contact is the point where a packaging project stops being a design exercise and becomes a controlled one. The material route, the additives, the coatings, the printing, the production environment and the paperwork all change once the pack meets food. THECA develops molded fiber for relevant food-contact applications the way it develops everything else — from the application backwards — and supports the project with the declarations and analyses that belong to it.
What you are starting from with THECA.
100% post-consumer recycled fiber
Every THECA product is moulded from post-consumer recycled cellulosic fibre, with the fibre route controlled and traceable.
PPWR compliant
Our products are PPWR compliant. Packaging-waste compliance and food-contact suitability are assessed separately, against different rules.
Documentation for relevant applications
Declaration of Compliance for food contact materials, Allergen Declaration and PFAS Analysis Report, issued for the scope they state.
ISO 9001 and FSC Recycled
A certified quality-management system and chain-of-custody traceability for the recycled fibre we use.
The EU framework
Two regulations apply to every food-contact pack, whatever it is made of.
Regulation (EC) No 1935/2004 is the framework for all food contact materials in the EU. Its core requirement is that a material must not transfer its constituents to food in quantities that could endanger human health, change the composition of the food unacceptably, or alter its taste, smell or appearance. It also covers labelling and traceability, and it lists seventeen groups of materials that may be covered by specific EU measures. Note that food contact includes indirect contact, not only a surface that touches the product.
Only a few of those seventeen groups actually have a dedicated EU measure: plastics, recycled plastics, active and intelligent materials, ceramics and regenerated cellulose film. Paper and board is not one of them. Where no specific EU measure exists, member states may complement EU law with their own national provisions — which is why the applicable requirements for a fibre-based food pack depend on which markets it enters, and why "compliant in Europe" is not a meaningful statement on its own.
Regulation (EC) No 2023/2006 on good manufacturing practice applies across all of these materials and all stages of manufacture, processing and distribution. It requires a quality assurance system, a quality control system and documentation, and it sets detailed rules for printing inks applied to the non-food-contact side so that substances are not transferred to the food-contact side by set-off or through the substrate. For a printed moulded fibre tray, that is a production-control requirement rather than a footnote.
Law, national rules and guidance
What is binding, what is national, and what is a recommendation.
| Layer | Example | Status | What it means for your project |
|---|---|---|---|
| EU framework legislation | Regulation (EC) No 1935/2004 and the GMP Regulation (EC) No 2023/2006 | Binding and directly applicable across the EU | Applies to fibre-based food packaging regardless of whether a material-specific measure exists |
| EU material-specific measures | Plastics, recycled plastics, ceramics, regenerated cellulose film, active and intelligent materials | Binding, but only for the materials they cover | Paper and board is not covered by a dedicated EU measure of this kind |
| National requirements | Provisions adopted by individual member states where no specific EU measure exists | Binding in the country concerned | Requirements can differ between your target markets, so the market list belongs in the brief |
| Technical recommendations | BfR Recommendation XXXVI on paper and board for food contact, whose scope expressly covers moulded fibre | A German technical recommendation, not binding EU legislation | Widely used as a reference point and frequently requested by customers as a benchmark |
| Company documentation | Declarations, analysis reports and supplier information | Issued by the manufacturer for a stated scope | Each document covers what it says it covers, for the use and conditions it was drafted for |
Scroll the table sideways on smaller screens to see every column.
Intended use defines the assessment
The same tray, two applications, two different questions.
There is no single answer that covers dry biscuits at ambient temperature and a fatty product held warm. Each variable below changes what has to be considered and what evidence is worth gathering. Treat this as a project-definition tool rather than an approval table.
| Project variable | Why it changes the assessment | What to state in your brief |
|---|---|---|
| Contact type | Direct contact, indirect contact and non-contact transport packaging are different cases under EU law | Whether the fibre touches the unwrapped product, or sits outside a primary wrap |
| Food type | Dry, moist, fatty and aqueous foods behave differently against a fibre surface | The actual product, not a category label |
| Contact duration | Momentary handling and long shelf-life storage are not comparable exposures | Expected contact time from filling to consumption |
| Contact temperature | Chilled, ambient, warm-fill and reheating conditions each change the technical question | The temperature range the pack will actually see |
| Storage and distribution | Humidity and cold chain affect both fibre performance and the contact situation | Storage conditions, humidity and transport route |
| Handling pattern | Single-use and repeated-handling applications imply different controls | How the pack is used, and by whom |
| Barrier or coating | Any added layer becomes part of the assessment subject, not a detail on top of it | Whether a barrier is genuinely required, and for what |
| Documentation | The scope of a declaration or analysis has to match the application it supports | Which declarations, analyses or tests your customers and auditors expect |
Material and process
Recycled fibre and food-contact suitability are two questions, answered together.
Recycled fibre content does not establish food-contact suitability, and it does not rule it out either. They are separate technical considerations, and they are addressed the same way any controlled specification is: through input control, process control, documentation and application-specific evaluation. BfR Recommendation XXXVI, for instance, sets out preconditions for the use of recycled fibres and identifies substances that warrant particular attention in the finished article — a technical reference rather than a legal grant, but a useful structure for a fibre project.
- Fibre source and grade selection. Which recovered grades enter the process, and how that input is controlled and traced.
- Process hygiene and environment. The production conditions the GMP Regulation expects to see documented.
- Additives and process aids. Reviewed against the intended use rather than carried over by default.
- Coatings and barriers. Any added layer becomes part of the article being assessed.
- Inks and printing. Coverage, placement and the set-off question the GMP rules specifically address.
- Adhesives and added components. Labels, closures and fixings belong in the assessment, not outside it.
- Migration potential. Considered against the actual food, contact time and temperature.
- Traceability. Batch-level traceability so a question about a delivery can be answered.
The practical consequence: the moulded body and the finished construction are different assessment subjects, and the finished construction is the one that matters.
PFAS, allergens and supporting evidence
Three documents that strengthen a technical file.
PFAS Analysis Report
Since 12 August 2026, Regulation (EU) 2025/40 restricts placing food-contact packaging on the EU market where PFAS are present at or above defined limit values, with no transitional period for exhausting stocks. Fibre packs are squarely in scope because fluorinated chemistry has historically been used for grease and water resistance. Our report evidences THECA's testing and verification approach.
Allergen Declaration
Food producers carry their own allergen-management obligations, and packaging suppliers are routinely asked to support them. An allergen declaration gives your quality team a documented supplier position instead of an email thread.
Independent Intertek analyses
Independent laboratory work on selected products adds third-party evidence to the file. As with every document here, the analysis covers the sample and conditions it names — which is precisely why the scope should be matched to the application before it is relied on.
A Declaration of Compliance for food contact materials is available for relevant applications, drafted for the product and use it covers. It is a supplier statement with a defined scope, not a blanket approval for every food type and condition.
Documentation pathway
Seven steps from food type to approved series design.
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01
Define the food and contact conditions
Product, contact type, duration, temperature and storage. Everything downstream depends on getting this stated precisely.
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02
Confirm the complete construction
The moulded body plus every coating, ink, adhesive, label and added component that will be part of the finished pack.
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03
Review material and process documentation
Fibre input controls, production conditions and the supplier information behind them are reviewed against the stated use.
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04
Identify relevant testing
Test scope is set by the application and target markets, not by habit. Agreeing it early avoids testing the wrong construction.
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05
Produce and evaluate samples
For technically suitable projects, a complete brief reaches a first sample in about four weeks — in the construction you intend to run.
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06
Finalise application-specific documentation
Declarations and analyses are aligned to the approved construction, the intended use and the markets involved.
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07
Release for series production
Specification, inspection points and packing configuration are fixed. Typical lead time is 2–4 weeks after final approvals and a confirmed order.
Buyer checklist
Bring these eleven answers and the first reply will be technical.
- Food type and product
- Direct or indirect contact
- Contact duration and temperature
- Storage and transport conditions
- Product dimensions and weight
- Barrier or moisture-resistance requirements
- Printing and adhesive requirements
- Target countries
- Annual quantity — series projects start from around 10,000 units
- Declarations, analyses or testing your customers expect
- Packing-line, denesting and logistics requirements
How THECA supports the project
Engineering, tooling and documentation in one organisation.
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01
Application and process review
We establish the contact situation first, then select Type 1, 2 or 3 from the surface, tolerance and load requirements. See how THECA produces molded fiber.
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02
Structural design and tooling
Cavities, ribs and clearances are developed around the product, with molds built in our own shop. Browse the molded fiber product range.
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03
Sampling and validation
Fit, packing sequence and handling are trialled with the real product, with ISTA drop testing where a project requires it. See food and beverage applications.
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04
Documentation and supply
Relevant declarations and analyses are aligned to the approved design, alongside our certificates and analysis reports.
Related compliance topics
Frequently asked
Three questions food producers ask first.
Is every molded fiber pack automatically suitable for food contact?
No, and THECA does not present its range that way. Food-contact suitability is an application-level question that depends on contact type, food, time, temperature, the complete construction and the target markets. Many of our products are protective or transport components that never touch food. For applications where contact is intended, we evaluate the case and issue documentation for the scope it covers.
Can recycled fibre be used in food-contact applications?
Recycled fibre content neither establishes nor excludes food-contact suitability — it is a separate technical question answered through input control, process control and application-specific evaluation. Technical references such as BfR Recommendation XXXVI set out preconditions for the use of recycled fibres and identify substances that deserve particular attention in the finished article. That is the structure we work to, alongside the GMP requirements that apply to production.
What information do you need to evaluate a food-contact project?
The food and whether the fibre touches it, the contact time and temperature, storage and distribution conditions, product dimensions and weight, any barrier or printing requirement, your target countries, expected annual volume and the declarations or testing your customers ask for. With that we can say whether the application is one we can support, what the construction should look like, and which documents belong with it.
Official sources
- EUR-Lex — Regulation (EC) No 1935/2004 on food contact materials
- EUR-Lex — Regulation (EC) No 2023/2006 on good manufacturing practice
- European Commission — Food Contact Materials
- EFSA — Food contact materials and specific measures
- BfR — Recommendation XXXVI, paper and board for food contact
- EUR-Lex — Regulation (EU) 2025/40, including the PFAS limits for food-contact packaging
- European Commission JRC — EU Reference Laboratory for Food Contact Materials
Last reviewed: 15 September 2026
This page provides general technical information and does not constitute legal advice. Requirements should be assessed for the specific product, market and intended use.
Next step
Discuss your food-contact molded fiber packaging project.
Send the product and food type, whether contact is direct or indirect, the expected contact time and temperature, your target markets, the annual quantity, any barrier requirement and the documentation or testing your customers ask for. Our engineers will tell you whether the application is one we can support, what the construction should look like, and which declarations and analyses belong with it.