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.
Two regulatory regimes, two questions
| 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?" |
Specification note: Figures such as particle-size brackets, heavy-metal limits and MOQ are shown as typical industry ranges; confirm final values against the COA/TDS for your batch.
Converter's pre-production checklist
- Confirm the layer position. Is the pigmented coating on the food side, or separated by a functional barrier? Barrier design changes the evidence you need.
- Request the right declaration. A food-additive COA does not prove food-contact compliance; ask specifically for the food-contact statement and any migration data.
- Lock the pigment grade. Changing grade later can re-open the compliance file — specify lot-level traceability.
- Document the converter process. Heat, solvents and lamination in your line can affect the pigment layer; keep a process record.
Q: Can I use our food-grade pearl directly in a food-contact coating?
A: 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.
Q: Does E171-free matter for packaging?
A: 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.
Sources: Commission Regulation (EU) 10/2011 FDA food-contact provisions 21 CFR Commission Regulation (EU) 2022/63 E171 ISO 787 .
SC
Technical Director, EFFECT-PIGMENT — writes on pigment specification, compliance and application engineering.
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