Food contact compliance for aluminium foil
Every supplier says "food grade". Almost none can tell you what that means in your market, which document proves it, or what happens when a retailer asks for the evidence three months after delivery.
Compliance is not a certificate — it is a declaration plus a migration test report plus a material specification, matched to your market and your intended use conditions. The US works through the FDA's indirect food additive framework, the EU through Regulation (EC) 1935/2004 with GMP Regulation 2023/2006 and Council of Europe guidance on metals and alloys, and Germany through LFGB. A supplier who offers a logo instead of a test report has not answered the question.
Aluminium foil is not a complicated food contact material. It is a single-layer metal with no plasticisers, no curing agents and nothing to migrate except the metal itself and any surface treatment. That simplicity is why compliance is achievable — and why a supplier who cannot document it is probably not testing at all.
What "food grade" is actually asking
Three separate questions hide inside the phrase:
- Is the material suitable? Alloy, purity, absence of harmful contaminants, no recycled content of unknown provenance.
- Does anything migrate into food? Aluminium transfer, plus residuals from rolling lubricants, coatings or printing inks.
- Is there evidence? A test report from an accredited laboratory, under conditions matching real use.
The third is where most supply chains fall down. The first two are usually fine for a well-run plant; the paperwork trail is what a retailer audits.
United States
There is no single FDA regulation that says "aluminium foil". Food contact materials are handled as indirect food additives under the framework in 21 CFR Parts 174–178, and the compliance route depends on what the foil actually is:
- Bare foil — assessed as a food contact substance; suppliers typically provide a declaration and migration data.
- Coated foil — the coating is a separate regulated entity, and 21 CFR 175.300 (resinous and polymeric coatings) is commonly cited for that layer.
- Printed foil — printing inks must be formulated for food contact and must not set off through the substrate.
Practically, what a US buyer should hold is a supplier declaration plus a migration test report, and clarity on whether any coating or ink is present. Be sceptical of a document that cites a regulation number without test data behind it.
European Union
The EU framework has three layers, and buyers usually only see the first.
| Layer | Instrument | What it requires |
|---|---|---|
| Framework | Regulation (EC) No 1935/2004 | Materials must not transfer constituents in quantities that endanger health or alter food |
| Good practice | Regulation (EC) No 2023/2006 | GMP for food contact materials — documented quality assurance |
| Material-specific | Council of Europe guidance on metals and alloys, plus national measures | Alloy composition, metal release limits, testing conditions |
Because the EU has no harmonised specific measure for metals and alloys, national rules fill the gap — which is why a German retailer and a Spanish retailer may ask for different documents for the same product. If your customer is a German discounter, expect the German requirement to be the binding one.
Under 1935/2004 the supplier must issue a written declaration of compliance. It should name the article, the regulation relied on, the intended use conditions (temperature, contact time, food type) and the basis for conformity. A one-line "we confirm food grade" letter is not a declaration of compliance.
Germany: LFGB
The German Food and Feed Code (LFGB) applies alongside the EU framework, with the Federal Institute for Risk Assessment (BfR) publishing recommendations for specific material classes. German retailers and discounters treat LFGB conformity as a baseline requirement, and their auditors will ask for it by name.
If you sell into Germany — directly or through a distributor who sells there — specify LFGB in the purchase order. It costs little to test for and a great deal to discover missing after the pallets have shipped.
What to ask your supplier for
- Declaration of compliance, naming your product and your market's regulation.
- Migration test report from an accredited laboratory, with the test conditions stated — temperature, duration, simulant.
- Material specification — alloy, temper, whether any coating or printing is present.
- Mill test certificate, separate from the above — it is a quality document, not a compliance one.
- Confirmation of virgin material — no post-consumer recycled aluminium in food contact foil.
Check the test conditions before the result. A migration test run at 20 °C for two hours does not support an oven-liner claim, and a report for a 12 μm plain foil does not cover a 20 μm coated one. The result is only valid for the sample and the conditions tested.
Who pays for testing
Usually the buyer, and that is reasonable. Testing is specific to a product, a market and a use condition, so a supplier who pre-tests everything either charges for it in the unit price or tests to the lowest common denominator. We quote testing separately for exactly this reason: so a customer buying for a market that does not require a given report is not paying for it.
Frequently asked questions
Is aluminium foil safe for direct food contact?
Yes, at food-contact grade and within the destination market's migration limits. Aluminium foil has been used in direct contact for decades. The compliance work is about documenting alloy purity, absence of harmful residuals and acceptable metal release — not about aluminium being inherently unsuitable.
Can I print my brand on foil that touches food?
Only with food-contact-compliant inks and a substrate that prevents set-off. In practice most retail foil is printed on the carton rather than the foil, which avoids the question entirely — see packaging design.
Does recycled aluminium affect compliance?
It can, through contamination risk. Food contact foil should be made from virgin or controlled-scrap material with documented provenance. Ask the question directly — a supplier who cannot answer it has not considered it.
Sources
- Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food.
- Commission Regulation (EC) No 2023/2006 on good manufacturing practice for food contact materials.
- Council of Europe, Resolution CM/Res(2013)9 on metals and alloys used in food contact materials.
- 21 CFR Parts 174–178, US Food and Drug Administration.