A converter adding visual effect to packaging faces a subtle but critical distinction: a pigment that is safe as a food additive is not automatically cleared for every food-contact use, and vice versa. This checklist keeps the two regimes separate.
| Regime | Question it answers |
|---|---|
| Food additive (e.g., E-number / 21 CFR 73) | "May this pigment be eaten?" — for decorative dust on food itself |
| Food-contact material (e.g., EU 10/2011, FDA food-contact) | "May this pigmented layer touch food packaging without migrating?" |
Q1: Can I use our food-grade pearl directly in a food-contact coating?
Only if it carries the appropriate food-contact declaration for that use. Food-grade (additive) status and food-contact status are separate approvals — verify both before production.
Q2: Does E171-free matter for packaging?
E171 (TiO₂ as additive) rules govern pigment in food, not the packaging layer. For packaging, the relevant gate is food-contact migration compliance, which is a different test.
Q3: What is the difference between food-additive and food-contact compliance?
Food-additive status (for example an E-number or 21 CFR 73) answers “ may this pigment be eaten ” — for decorative dust on food itself. Food-contact status (EU 10/2011, FDA food-contact provisions) answers “ may this pigmented layer touch packaging without migrating ”. They are separate approvals; verify both.
Q4: What documents should I request for food-contact use?
Ask specifically for the food-contact declaration and any migration data — a food-additive COA does not prove food-contact compliance. Also hold the TDS, SDS and GMP statement, and specify lot-level traceability. See the food-grade pearl pigment specification pack.
Q5: Does a barrier layer change the evidence I need?
Yes. If the pigmented coating is separated from food by a functional barrier, the evidence required changes. Confirm the layer position (food side versus separated) before locking the compliance file; the food application guide covers typical layer positions.