Why do food export packaging companies need to understand national regulations?
Food packaging export is a complex process involving multi-country regulatory compliance. Different countries and regions maintain their own independent, strict management systems for food contact materials. The US has the FDA, the EU has EU 10/2011, Japan has the Food Sanitation Act, Australia has FSANZ standards, and Southeast Asian countries are building their own frameworks. For companies planning to export to these markets, understanding the target market’sexport packaging certification regulations is the first and most critical step. If you are not sure which certifications your product needs, you can first read ourPackaging knowledge articles to understand the basic concepts. This articlecombines packaging knowledge and, in the form of comparison tables, systematically presents the core regulatory requirements of the five major markets.
The US market: FDA food contact material regulations
US food packaging is regulated by the FDA, with Title 21 of the Code of Federal Regulations (21 CFR) as the core. The FDA manages food contact materials under the “food additive” concept — any packaging component that may migrate into food is treated as a food additive requiring FDA approval or GRAS (generally recognized as safe) status. The FDA requires packaging producers to provide migration test data proving safety under intended use conditions. Notably, the FDA has additional requirements for recycled materials — recycled plastics must meet the same purity standards as virgin materials. For food packaging exported to the US, obtainingexport packaging certification is the basic threshold.
The EU market: EU 10/2011 and the EFSA assessment system
The EU’s food contact material system is more systematized. EU 10/2011, the specific regulation for plastic food contact materials, establishes a positive list (Union List) of permitted monomers and other starting substances, with the European Food Safety Authority (EFSA) conducting scientific assessments. Unlike the FDA, EU rules also require companies to establish Declarations of Compliance (DoC) and keep supporting documents. The EU sets explicit limits for both overall migration (OML) and specific migration (SML). In 2023, the EU further tightened bisphenol A (BPA) restrictions, lowering its limit in food contact materials.
The Japanese market: the Food Sanitation Act and voluntary standards
Japan’s food contact material rules are based on the Food Sanitation Act, administered by the Ministry of Health, Labour and Welfare. The system includes specification standards (composition and migration limits for specific materials) and manufacturing standards (production process rules). Unlike Europe and the US, Japan’s framework emphasizes industry self-regulation. Associations such as JHOSPA (Japan Hygienic Olefin And Styrene Plastics Association) set voluntary standards that carry real weight in practice. When exporting food packaging to Japan, besides meeting legal requirements, obtaining certification from associations like JHOSPA significantly boosts market trust.
The Australian market: FSANZ standards
Australian and New Zealand food packaging rules are managed by Food Standards Australia New Zealand (FSANZ), applying uniformly to both countries. Australia’s system resembles the EU’s, emphasizing comprehensive assessment of substances that may migrate from food contact materials. FSANZ standards cover plastics, paper, glass, metal and other packaging materials. Like the EU, Australia requires Declarations of Compliance. Notably, Australia’s approach to chemicals in food packaging leans on risk assessment rather than simple substance bans. Exporters must run targeted compliance assessments based on the specific packaging material and food type.
The Southeast Asian market: an emerging regulatory system
ASEAN member states are at different stages in food packaging regulation. Thailand and Malaysia are relatively mature: the Thai FDA has issued standards for plastic food contact materials, and Malaysia references EU and Japanese frameworks. Indonesia’s rules are still developing — BPOM (the drug and food regulatory agency) has published general requirements for food packaging materials. Vietnam and the Philippines have simpler rules focused on basic safety. Exporters to Southeast Asia must confirm requirements country by country while watching the regulatory harmonization ASEAN is advancing.
Summary of the five-market regulation comparison
In regulatory philosophy, the US and EU take different paths: the FDA manages around food additives, focusing on ingredient safety; the EU centers on positive lists and migration limits, emphasizing systematic compliance. Japan combines legal requirements with industry self-regulation into a unique dual system. Australia’s system is close to the EU’s but more flexible. Southeast Asian countries have thin regulatory foundations but are developing fast. For would-be exporters, understanding the target market’s regulatory characteristics isexport packaging certification the first step. Consider target-market regulatory requirements during packaging design and material selection to avoid unnecessary hurdles at the export stage.
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