| 1 | Define the intended food-contact use | Specify whether the paper will contact dry food, moist food, fatty food, frozen food, hot food, or food exposed to heating. | The purchase specification clearly states the food type, contact time, temperature, and whether contact is direct or indirect. | Approved product specification and written end-use statement. |
| 2 | Check the applicable regulatory route | For the United States, assess suitability under FDA 21 CFR 176.170 where applicable to paper and paperboard in contact with aqueous or fatty foods. For the European Union, confirm compliance with the general safety requirements of Regulation (EC) No 1935/2004. | The compliance assessment matches the destination market and the actual food-contact conditions. EU requirements are supported by relevant national rules, industry guidance, or other applicable specific measures where required. | Market-specific declaration of compliance or regulatory assessment signed by a qualified person. |
| 3 | Verify the PE coating grade and coverage | Confirm the polyethylene type, coating weight, coating side, surface coverage, and whether the coating is continuous and free from exposed paper areas. | Coating details are consistent with the approved technical data sheet, drawings, and intended food-contact application. | Technical data sheet, coating specification, sample inspection, and coating-weight test results. |
| 4 | Review migration and extractives testing | Request testing that represents the intended food-contact conditions. For FDA applications, review the relevant extractives or suitability data. For EU sales, assess overall migration and any applicable specific migration limits under relevant EU measures. | Test conditions reflect the actual food simulant, temperature, contact duration, and food category. Results comply with the limits applicable to the intended use. | Independent laboratory report with sample identification, test method, conditions, detection limits, and results. |
| 5 | Confirm raw-material traceability | Trace the base paper, PE resin, additives, inks, adhesives, and processing aids from incoming materials through the finished roll or sheet. | Each bulk shipment has a unique lot number linked to production records and the corresponding raw-material batches. | Lot traceability procedure, batch records, certificates of analysis, and retention-sample records. |
| 6 | Assess odor, taste, and sensory neutrality | Check whether the coated paper could transfer undesirable odor or taste to food, especially in hot, fatty, or long-duration contact applications. | No unacceptable odor or taste is detected under conditions representative of the planned use. | Sensory test report, complaint history, and documented corrective-action process. |
| 7 | Verify physical performance during converting | Evaluate basis weight, caliper, stiffness, tensile strength, coating adhesion, heat-seal behavior, curl, and print or converting compatibility. | Measured values fall within agreed tolerances and the material runs consistently on the buyer's equipment without coating cracking, delamination, or excessive curl. | Pre-production trial results, certificate of analysis, and signed technical specification. |
| 8 | Control printing inks, adhesives, and recycled content | Identify all non-paper components and determine whether printing or adhesive layers are on the food-contact side. Review recycled-fiber controls and potential contaminants where relevant. | Food-contact and non-food-contact layers are clearly defined, and all components are covered by a documented safety assessment for the intended application. | Ingredient or component declarations, supplier compliance statements, ink and adhesive documentation, and risk assessment. |
| 9 | Establish incoming inspection and sampling | Set inspection rules for roll width, basis weight, moisture, coating defects, pinholes, contamination, packaging integrity, and lot consistency. | Sampling frequency, acceptance limits, and test methods are agreed before the first bulk shipment. Nonconforming lots are quarantined. | Incoming inspection plan, sampling record, nonconformance form, and corrective-action log. |
| 10 | Secure documentation and change control | Make continued compliance a purchase condition and require notification before changes to resin, additives, base paper, coating process, manufacturing site, or test status. | Documentation is current, revision-controlled, and renewed after a material or process change. The supplier can support recall and traceability obligations. | Quality agreement, change-notification clause, current compliance declaration, audit records, and recall procedure. |