Food contact materials are all materials and articles intended to come into contact with food, such as packaging liners and containers. These can be made from a variety of materials including plastics, rubber, paper and metal products, many of which are subject to regulation by FDA.  The term “food contact substance” (FCS) is defined by the Federal Food, Drug, and Cosmetic Act as “any substance intended for use as a component of materials used in manufacturing, packing, packaging, transporting, or holding food if such use is not intended to have any technical effect in such food.”  Examples of food contact substances include polymers (plastic materials), colorants, and antioxidants used in polymers, can coatings, adhesives, and other materials used to produce paper and paperboard, antimicrobial agents, and sealants for lids and caps.

Services:  HPM assists clients with a wide range of topics related to food contact substances, including the identification of the legal status of the packaging material (can you use it for food?), regulatory pathways available for a food contact substance, requirements for plastic forks and paper plates, as well as exemptions from FDA regulation.


  • Provided opinion letters on the compliance status of food contact products and their constituents
  • Assisted with submission of food contact notification
  • Conducted due diligence related to acquisition of food contact manufacturer
  • Determined requirements for antimicrobial wash
  • Advised regarding housewares exemption
  • Established authorization for use of colorant in food contact products