Safety standards for food contact that you need to know.

When packaging comes into direct contact with food, the materials must not migrate (i.e., transfer their components) into the food at levels harmful to health or alter its flavor. This is not a recommendation, but a legal requirement. Understanding this framework from the start helps you avoid wasting money on rework after the samples have been produced.

The foundational legal framework

In Vietnam, the standard regulations to be aware of are QCVN 12 from the Ministry of Health, categorized by material group:

• QCVN 12-1:2011/BYT: synthetic plastic, including limits on leaching tests for each type of polymer.
• QCVN 12-2: cao su.
• QCVN 12-3: metals.
• QCVN 12-4: glass and ceramics.

When you export to the European market, you must consider two separate frameworks: EC 1935/2004 (general principles for all materials in contact with food) and EU 10/2011 (specific for plastics). These frameworks require material suppliers to provide a Declaration of Compliance confirming that the product meets applicable regulations.

Materials must not transfer their constituents into food in harmful amounts, altering the composition or reducing the sensory quality of the food.

Regulation (EC) 1935/2004, European Commission

Factors affecting the level of contamination

Having standard materials is not sufficient. The actual contamination level depends on specific usage conditions. You need to consider:

• Type of food inside: oily foods, acidic foods, or those containing alcohol will extract more substances from the material than dry foods.
• Temperature and contact time: packaging for hot food or reheating must withstand harsher conditions than packaging used at room temperature.
• Type of polymer: each type of plastic has its own migration limits and testing conditions according to standards.
• Inner coating and ink layer: if this layer comes into direct contact with food, it must meet the same requirements as the main material.

When to need to check and who does it

You need to clearly differentiate two responsibilities: the design unit and the material production unit must specify the correct technical requirements, while testing and compliance certification belong to the testing lab and material producer.

Common mistakes when choosing materials

• Select materials for aesthetics first, check safety later: discovering non-compliant materials only at the announcement stage forces a complete redo.
• Using ink or inner coating not suitable for food contact: this point is often overlooked because the coatings look the same from the outside.
• No retention of compliance statements from suppliers: When regulatory agencies or import partners request documents, the lack of this material can cause delays or loss of shipments.
• Confusing "food-grade plastic" with "meeting QCVN 12": Suppliers may use unofficial terminology. You need to request specific compliance documents, not just verbal confirmations.

The viewpoint of Sinh Vũ

Sinh Vũ checks compliance at the stage of creating the die-cut mold, before the file goes to print. For food safety, Sinh Vũ includes material requirements and inner coating specifications for the printer and material supplier to confirm before production, rather than discovering issues late in the inspection stage.

This does not replace the responsibility of material producers and testing rooms. But it helps you avoid placing samples only to find out that you need to completely change the material.