Cling Film Food Contact Compliance: LFGB, FDA, EU 10/2011

Cling Film Food Contact Compliance: LFGB, FDA, EU 10/2011

Food contact compliance is the part of a cling film order that is easiest to postpone and most expensive to get wrong. A film can be perfectly made, correctly priced and delivered on time, and still be stopped at the border or rejected by a retail buyer because the paperwork does not match the market it was sold into. The regulation that applies is the one in force where the food is sold — not where the film was made.

This guide explains what cling film food contact compliance actually requires, what EU 10/2011, LFGB and FDA compliance each mean in practice, which documents a supplier should be able to provide, and how to check that a food grade cling film certificate covers the film you are buying rather than a different product. If you are specifying film for the first time, our guide to cling film thickness and cost per metre covers the specification side, and the private label cling film checklist covers the commercial sequence.

What Food Contact Compliance Actually Means

A food contact material regulation does two things. It lists which substances may be used in a material that touches food, and it sets limits on how much of those substances may transfer into the food. Compliance means both conditions are met: the formulation is permitted, and the transfer — measured by a migration test under defined conditions — stays within the limits.

For cling film this is more demanding than it sounds, because the film is a thin, flexible plastic in direct contact with food, often with a plasticiser added to keep it soft and a stabiliser added to keep it from degrading. PVC Cling Film in particular is plasticised, and plasticisers are exactly the class of substance that regulators watch most closely. The thinner the film, the more surface area it presents per unit of food, which is why migration limits are expressed per unit of surface area rather than per unit of weight.

It also means compliance is product-specific. A certificate issued for one film at one thickness does not automatically cover a different formulation, a different gauge or a film made for a different market. This is the single most common misunderstanding in the category, and it is why the document check below matters more than the presence of a certificate.

The Three Standards Buyers Ask About Most

Most export enquiries name one of three standards. They are not interchangeable, and a supplier who answers all three with a single document is telling you something about how carefully they have read the question.

The distinction that trips buyers up is the last row. The US FDA does not issue food contact certificates to factories. Compliance is declared by the resin supplier or converter against the regulation, and a factory claiming an "FDA certificate" for cling film is usually holding a statement, not a certificate. That is normal — but it should be described honestly, and you should be able to see what it actually says.

An LFGB cling film test is popular with European importers because it goes further than the minimum EU requirement. Alongside the migration limits, an LFGB test typically includes an odour and taste assessment, which is a practical test of whether the film will taint the food it touches. For a product used on fresh produce and prepared meals, that sensory check is not a formality.

What Documents a Cling Film Supplier Should Provide

A compliant order normally comes with a small set of documents rather than one. Knowing what each one is for tells you which to ask for and which answers to expect.

Ask for the set before the order, not after. A supplier who can send the documents in a single reply has them on file; one who needs several days to produce them may be arranging testing for the first time, which changes your lead time as well as your risk.

How to Read a Food Contact Declaration of Compliance

A food contact declaration of compliance is only useful if it is specific. Six details turn a one-page statement into something you can rely on, and any that are missing should be questioned.

• The identity of the material. "Cling film" is not enough. It should name the polymer — PVC or PE — and the formulation or product code.
• The thickness or product range covered. If your order is 10 micron and the declaration covers 15 to 20 micron, it does not cover your order.
• The food types it is cleared for. Fat content and acidity both change migration, so a declaration limited to aqueous foods will not support a film used on cheese or meat.
• The conditions of use. Storage temperature, whether the film may be microwaved, and the maximum contact time all belong on the document.
• The regulation it is issued against. EU 10/2011, LFGB or 21 CFR Part 177, named explicitly rather than referred to as "international standards".
• A date and an identifiable issuing party. An undated declaration cannot be checked for currency, and regulations are amended.

Send that list to your supplier and you will learn quickly how well they know their own documentation. It is also worth comparing the declaration against the migration test report. The declaration states the conclusion; the report shows the measurements behind it, and the two should agree on the material, the thickness and the test conditions.

What Does a Migration Test Actually Measure?

A cling film migration test simulates what happens when film sits against food. A sample is exposed to a food simulant — a liquid chosen to represent the fat, acid or alcohol content of the food in question — for a defined time and at a defined temperature. The laboratory then measures how much material has transferred into the simulant.

Two results matter. Overall migration is the total mass transferred, and EU 10/2011 cling film testing sets that limit at 10 mg per square decimetre of film surface. Specific migration is the quantity of one named substance, such as a plasticiser or a residual monomer, measured against its own limit. A film can pass the overall test and still fail on a single substance, which is why the specific results are the ones worth reading in full.

The conditions used in the test are as important as the results. A film tested for two hours at room temperature is not the same product as one tested for ten days at 40°C, and neither is the same as one cleared for oven use. Check that the test conditions match how your customers will actually use the film, because that is the use the regulation is applied to.

Who Is Responsible — the Factory or the Importer?

The legal duty normally sits with the business placing the material on the market, which in a private label arrangement is the brand owner or importer, not the factory. The factory supplies the film and the evidence; the brand owner is answerable to the regulator if the film turns out not to comply.

In practice this means you cannot delegate the question, only the testing. A sensible arrangement is that the supplier provides the declaration and the migration data, and you keep both on file, reviewed against the current version of the regulation. When a retail customer audits you, that file is what they will ask for — and a supplier statement with no test data behind it is a weak answer at that point.

Our films are supplied with EU and LFGB certification and we provide the accompanying documents for the specification ordered. If your market adds requirements beyond those — a national scheme, a customer specification, a residue limit — tell us at the enquiry stage so the film is specified for it rather than tested for it afterwards.

Frequently Asked Questions

Is cling film food safe by default?

Not automatically. Food safety depends on the formulation and on the certification that goes with it. Film manufactured as a food grade cling film and supplied with a declaration of compliance and migration data is suitable for direct food contact within the stated conditions. Film made for industrial wrapping may look identical and is not intended for food.

What is the difference between EU and LFGB certification?

EU 10/2011 is the baseline regulation for plastic food contact materials sold in the European Union. LFGB testing is carried out against German requirements, which sit on top of that baseline and add elements such as sensory assessment. European importers often ask for both, because LFGB is widely treated as the more demanding of the two.

Can a supplier give me an FDA certificate for cling film?

The FDA does not issue certificates of that kind to factories. US compliance is declared against the relevant part of 21 CFR Part 177, supported by statements from the resin and additive suppliers. If you are offered a certificate, ask to see the underlying compliance statement and check which polymer and which regulation it references.

Does cling film compliance expire?

A declaration of compliance carries the date it was issued and applies to a defined product. Regulations are amended, formulations change, and a test carried out several years ago may no longer reflect either. Review the documents when the regulation changes or when the specification changes, and ask for batch-level confirmation on each shipment.

Conclusion

Cling film food contact compliance is a documentation exercise as much as a manufacturing one. The regulation that matters is the one in the market where the food is sold; the evidence that matters is a declaration that names the material, the thickness, the food types and the conditions of use, backed by migration data from a third-party laboratory. Everything else is marketing.

Tell us the market, the food type and the intended use. We will confirm which certification route applies, send the documents that go with it, and quote the film against the food-grade specification you actually need.