Food Contact Paper Compliance UK | Buyer's Guide | GMLUK

Food Contact Paper Compliance — UK Buyer's Guide

If you're sourcing paper packaging for a UK food business, the compliance landscape is fragmented across UK retained EU law, sector-specific industry standards (BRCGS), product-specific testing regimes, and supplier-specific certification claims. This guide unpacks what's actually required, what's nice-to-have, and what a clean compliance document package looks like.

The regulatory framework — what's actually mandatory

UK food contact paper packaging compliance is anchored on a small number of regulations, all retained in UK law post-Brexit with minimal divergence to date.

Framework Regulation (EC) 1935/2004 (UK retained)

The umbrella regulation. Establishes that:

• Materials and articles in food contact must not transfer constituents to food in quantities that endanger health

• Materials must not change food composition, taste or smell unacceptably

• Materials must be manufactured according to Good Manufacturing Practice (GMP)

• Manufacturers must provide a written Declaration of Compliance for food-contact materials

This is the foundational requirement. Every UK food packaging material — paper, plastic, glass, metal, ceramic — must comply.

Good Manufacturing Practice Regulation (EC) 2023/2006 (UK retained)

Specifies how food-contact materials must be manufactured:

• Quality assurance system covering ingredients, processes and finished goods

• Documented procedures for non-conforming product

• Training and personnel competence

• Traceability throughout the production chain

Most BRCGS-certified packaging manufacturers comply with GMP requirements as part of their standard quality management system.

Commission Regulation (EU) 10/2011 (UK retained)

Specifically for plastics in food contact, but used as the reference framework for migration testing of paper packaging too — the food simulants and migration limits in 10/2011 are the practical standard against which paper compliance is tested.

Migration limits for substances are set under the Specific Migration Limit (SML) regime, with most substances limited to 60 mg/kg of food (the overall migration limit) and specific compounds at lower limits.

BfR Recommendation XXXVI (German federal recommendation)

Not UK law, but the de facto reference for paper-specific food contact compliance. BfR XXXVI (Paper and Board for Food Contact) specifies:

• Permitted starting materials for paper manufacture

• Restrictions on additive types and quantities

• Specific limits for chemical residues

• Migration test procedures specific to paper

Most UK paper suppliers reference BfR XXXVI as the compliance standard for food contact, alongside EC 1935/2004 declarations.

EuPIA Exclusion List for Printing Inks

The European Printing Ink Association maintains an exclusion list of substances that must not be present in inks used for food packaging. This list is updated regularly and covers:

• Phthalates and phthalate analogues

• Certain photoinitiators (notably ITX, benzophenones in some applications)

• Mineral oil aromatic hydrocarbons (MOAH)

• Certain colorants and pigments

• Heavy metal compounds beyond very low limits

Printing inks for food packaging must comply with the latest EuPIA exclusion list, with documentation traceable to the ink manufacturer.

BRCGS Packaging Materials Issue 7

The dominant industry-led certification standard for packaging manufacturers in the UK. Issue 7 is the current version (Issue 8 is in consultation as of 2026).

What BRCGS requires of certified packaging manufacturers:

1. HACCP-based hazard and risk analysis for the manufacturing process

2. Documented quality management system with traceability

3. Site standards covering layout, hygiene, pest control, building maintenance

4. Product control including specifications, testing, complaint management

5. Process control including monitoring of critical parameters

6. Personnel competence training, hygiene practices, contractor management

Major UK food retailers and brands typically require BRCGS certification from their packaging suppliers as a minimum prerequisite. Without it, you're typically excluded from supplier consideration regardless of price or technical capability.

GMLUK holds BRCGS Packaging Materials certification — see our quality control page for the current grade and audit history.

Print and ink compliance specifically

Where paper is printed for food packaging, three compliance considerations stack on top of the substrate compliance:

1. Ink composition (EuPIA + retailer-specific lists)

Ink components must comply with the EuPIA exclusion list. Some retailers maintain their own additional restricted substances lists (e.g. Tesco Restricted Substances List, M&S Plan A criteria) — verify your supplier complies with the relevant retailer list if you're supplying retail.

2. Print position

Direct food-contact prints have stricter migration requirements than non-contact prints. Most UK food-grade printed paper has the print on the outside (non-contact) face only, but this must be verified per application and tested where uncertainty exists.

3. Migration testing

Where printed paper is in food contact (directly or indirectly), migration testing demonstrates compliance with SML limits. Tests typically use:

• Distilled water (aqueous food simulant)

• 3% acetic acid (acidic food simulant)

• 10-50% ethanol (alcoholic food simulant)

• Olive oil or isooctane (fatty food simulant)

Test conditions specify temperature and contact time matched to the realistic application.

What a clean compliance document package looks like

For each food-grade paper specification you procure, your supplier should provide:

If a supplier can't produce any of these on request, treat it as a red flag — either compliance isn't being properly maintained, or the supplier doesn't fully understand what they're selling.

How UK and EU compliance differ post-Brexit

To date, UK retained EU law on food contact materials is essentially identical to current EU regulation. The areas to watch:

1. Future divergence — UK could in principle adopt different limits or different excluded substances. As of 2026 there is no significant divergence in force

2. Ink and additive lists — EuPIA is European; UK suppliers continue to work to it but a UK-specific list could emerge

3. CE-equivalent labelling — UKCA marking is for technical safety regulations; food-contact materials don't typically carry either CE or UKCA marks

4. Border declarations — UK-EU trade in food packaging requires SPS / customs declarations referencing compliance status

For UK B2B procurement targeting domestic supply only, the practical position is: same standards, same documentation, same suppliers as before Brexit.

For UK suppliers exporting to EU, an active EU contact for compliance correspondence (an "Authorised Representative" equivalent under EU food contact regulation) may be required for some products and customers.

How to procure for compliance

A clean food-contact paper procurement RFQ asks for the following:

1. Substrate — paper grade, GSM, source

2. Coating / treatment — wax type, silicone, aqueous coating, treatment chemistry

3. Print — colours, ink supplier, EuPIA confirmation

4. Compliance documents required — DoC, BfR statement, migration test, BRCGS cert, FSC cert, EuPIA statement

5. Annual volume and forecast — affects MOQ and pricing tier

6. End application — food type, contact conditions, storage temperature, duration

7. Customer requirements (retailer-specific) — Tesco RSL, M&S Plan A, Waitrose, etc.

The fastest quote happens when all seven are in the RFQ.

Common compliance mistakes in B2B procurement

1. Buying on price without verifying compliance documents — the cost of a recall and audit failure dwarfs the per-tonne cost difference

2. Assuming "food grade" claims mean compliance — verify the actual documents, including currency of the BRCGS certificate

3. Forgetting to check ink compliance separately from paper — the substrate may be compliant but the printing ink not

4. Not specifying contact conditions — "food contact" is a spectrum from dry biscuits to high-fat warm food; testing requirements differ

5. Skipping migration testing for borderline cases — when doubt exists, test. The cost of testing is small vs the cost of being wrong

6. Importing without verifying compliance to UK retained law — EU CE marking ≠ UK food contact compliance for imported packaging

How GMLUK approaches food-contact compliance

We supply food-contact paper packaging across our greaseproof, waxed and printed product lines. Our compliance approach:

• BRCGS Packaging Materials Issue 7 certified

• DoC issued with every food-contact order

• EuPIA-compliant ink stewardship — we blend inks on site from compliant components

• Migration testing on request via accredited UK laboratories

• FSC Chain of Custody certified

• BfR XXXVI alignment for paper-specific compliance

• Traceability through GMP-compliant manufacturing system

For applications with retailer-specific compliance requirements (Tesco RSL etc.) we have established protocols for verification. Talk to us about specifics.

Bottom line

UK food contact paper compliance is a clear, well-documented framework. The mandatory elements are EC 1935/2004 (retained), EuPIA inks, and BRCGS-equivalent quality standards. Where doubt exists, migration testing closes the gap.

The expensive mistakes happen when buyers either don't ask for the documentation, or accept marketing claims as evidence of compliance. A 30-minute compliance review at procurement saves a 3-month recall investigation later.

Browse our food-grade paper range Talk to our compliance team

Related

• Greaseproof paper

• Printed greaseproof paper

• Waxed paper

• Quality control and testing

• Material selection guide

• Sustainability — FSC and chain of custody