Why disposable knives and forks must undergo FDA food contact material testing
Date：2025-07-29 10:07:25 Classification
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Why Disposable Cutlery Must Be Tested for Food Contact Materials by the FDA
Disposable cutlery (plastic, PLA, paper coating, etc.) is considered "food contact material" when exported to the United States and must demonstrate that it will not migrate harmful substances into food under normal use. The US FDA, in accordance with the Federal Food, Drug, and Cosmetic Act and regulations 21 CFR Parts 174-186, requires all disposable tableware that comes into direct contact with food to undergo compliance testing; otherwise, it will not be cleared for marketing.
I. Applicable Materials and Typical Products
- Plastics: Disposable cutlery, spoon, and fork sets made of PP, PS, PLA, and PBS
- Paper Coatings: Paper handles with PLA-coated cutlery, pulp molded cutlery
- Biodegradable Materials: Corn starch-based and bagasse-based disposable cutlery
All materials must be tested according to 21 CFR Part 177 (polymers), Part 176 (paper/paperboard), and Part 178 (additives).
II. Core Testing Items and Limit Requirements
1. Overall Migration Limit (OML): ≤10 mg/dm²
2. Specific Migration Limit (SML): e.g., lead ≤0.01 mg/kg, cadmium ≤0.005 mg/kg, bisphenol A ≤0.05 mg/kg
3. Sensory Testing: No odor, no visible discoloration
4. High Temperature/Oil Simulation: Immerse in 4% acetic acid or n-heptane at 100°C for 2 hours to test migration
5. Phthalates Prohibited: 6 plasticizers, including DEHP, DBP, and DINP, must not be detected (effective from May 19, 2022)
III. Testing Process and Cycle (Updated for 2025)
1. Documentation: Formula, material SDS, production process flow chart, intended use conditions (temperature, time, food type)
2. Sample Requirements: 6 samples from the same batch Complete set of cutlery, with outer packaging
3. Laboratory testing: Migration and ingredient screening completed within 5–7 working days
4. Report and compliance statement: Issue FDA compliance report (valid for 1 year)
5. Subsequent maintenance: Retest at least once a year; re-evaluation required if formula or supplier changes
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