Food packaging

Food packaging is classed as a food contact material. This includes not only packaging itself, but also other materials and articles that are intended to come into contact with food during production or use. Examples include:

• cookware/ceramic ware
• cutlery /crockery
• work surfaces
• food processing equipment and machinery

How food contact materials are regulated

In line with the Windsor Framework, food contact materials (FCMs) in Northern Ireland are regulated under Regulation (EC) 1935/2004, which is enforced by the Materials and Articles in Contact with Food Regulations (Northern Ireland) 2012.

The regulation requires that materials:

• do not transfer their constituents into food at levels that could endanger human health
• do not bring about an unacceptable change in the composition of the food
• do not adversely affect the taste, smell or quality of the food

The regulation applies across the entire food chain and covers all materials intended to come into contact with food.

Some categories of FCMs are subject to additional, more detailed controls, including:

• 'active' materials, which release substances into food to extend shelf-life or condition
• 'intelligent' materials, which monitor or react to food conditions
• plastics and plastics recycling processes for food contact use
• ceramics
• regenerated cellulose film

There are also specific rules for certain substances and materials, including BADGE, BFDGE and NOGE, vinyl chloride monomer, adhesives and coatings.

FCMs authorisation

Businesses seeking authorisation to place new food contact materials on the Northern Ireland market must continue to follow EU food contact material rules.

Under the Windsor Framework, the Northern Ireland Retail Movement Scheme (NIRMS) allows pre-packed retail goods from Great Britain (including FCM-packaged food) to enter Northern Ireland using UK public health standards instead of EU standards, but only for NI final sale (requires ‘Not for EU’ label).

The Food Standards Agency (FSA) is the lead authority for food contact materials policy in NI, advising food businesses on safe packaging use, and safeguarding the public from chemical migration risks. Local councils are the enforcement bodies for FCMs in Northern Ireland and also have a role in advising businesses.

Adhesives are often used in food packaging to attach labels, seal flexible packaging (including wrappers, pouches and lidding) and laminate layers of food contact materials.

Several chemical substances are present in adhesives. When used in food packaging, these substances could transfer or migrate into food. Fatty or acidic foods and high temperatures can speed up this process, potentially affecting taste or exceeding safe limits set by food safety regulations.

Legal requirements for adhesives in food packaging

Adhesives count as food contact materials (FCMs) under EU regulation enforced in Northern Ireland through the Materials and Articles in Contact with Food Regulations (Northern Ireland) 2012.

The regulation requires that adhesives do not:

• make food harmful to health
• change the food’s composition unacceptably
• affect food taste, smell or quality

Adhesives must use authorised substances only, with migration testing if direct contact with food is possible. Their packaging should specify whether they are for ‘indirect contact only’, the temperature limits, or food type restrictions (eg ‘not for fatty foods’).

Packaging manufacturers and material suppliers are responsible for overall compliance, and ensuring adhesives comply with food contact material legislation. Food businesses should source adhesives from reputable suppliers, must retain supplier declarations of compliance and follow any usage instructions or restrictions.

Local councils enforce food safety rules via environmental health officers and can request compliance documentation during inspections.

Aluminium occurs naturally in some foods through soil and water uptake. Tea leaves, some herbs and spices, and leafy vegetables like spinach typically contain higher levels of aluminium than most other foods. Aluminium can also migrate into food from cooking utensils, foil, and packaging, or during prolonged cooking/storage.

The Food Standards Agency regularly monitors dietary exposure to aluminium and has found that average intake levels are well within international safety guidelines.

Regulating aluminium in food contact materials 

Aluminium counts as a food contact material (FCM) under EU regulation enforced in Northern Ireland through the Materials and Articles in Contact with Food Regulations (Northern Ireland) 2012.

This means that products that contain aluminium and are intended to contact food (like cookware, foil and foil containers and trays, and beverage cans) must satisfy strict FCMs rules around health risks, food composition changes, and impact on taste, smell or quality of food from migration.

To ensure compliance, businesses must use only food-grade aluminium, such as alloys marked 1050 or 3003, and get a declaration of compliance from any suppliers. This document confirms the aluminium meets safe migration levels. Local council enforcement teams may request these documents and check aluminium use (alongside other FCMs) during routine food hygiene inspections.

Safely using foil and aluminium cookware

Studies have shown that cooking foods in aluminium containers increases aluminium content in food, but only by a very small amount. Foil trays and pans are considered safe when used correctly.

Avoid using aluminium with acidic foods like tomatoes, rhubarb or citrus, as they may cause it to migrate into food more quickly. This happens because acids break down the protective oxide layer on aluminium surfaces. Prolonged contact increases transfer amounts, potentially affecting food taste and raising migration above recommended safety levels.

Bisphenol-A (BPA) is a chemical used in the manufacture of certain plastics and resins, including food contact materials (FCMs) like refillable drinks bottles, food storage containers, kitchenware, and protective coatings inside metal food and drink cans.

BPA can migrate into food from these materials, especially when heated, in contact with acidic or fatty foods, or over prolonged storage, potentially raising exposure levels above safe limits.

BPA and health risks

BPA is classed as an 'endocrine disrupter' - a substance that may interact with human hormone systems. Because of its potential to harm reproductive and endocrine health, BPA was previously subject to specific migration limits as an authorised substance for food contact plastics under EU Regulation 10/2011, and its use was subsequently banned from baby bottles, cups and beakers, and packaging for infant formula and baby food.

Full ban on the use and trade of Bisphenol A

From 20 January 2025, Commission Regulation (EU) 2024/3190 prohibits the use and trade of BPA, its salts, analogues and derivatives in all food contact materials (FCMs) across the EU.

The ban applies to the use of BPA (and other harmful bisphenols) in the manufacture of the following groups of FCMs and articles:

• adhesives
• rubbers
• ion-exchange resins
• plastics
• printing inks
• silicones
• varnishes and coatings

Limited allowances exist where no safe alternatives are available, such as specific plastic filtration membranes for microbiological safety. These remain under review.

For most products, there is an 18-month transition period to allow the industry to adapt and avoid disruptions to the food chain. Read about the EU ban on BPA in food contact materials and its related transitional provisions.

Northern Ireland position

Under the Windsor Framework, the EU ban on BPA and similar bisphenols applies in Northern Ireland.

If your business handles food packaging and FCMs, you should audit your supply chain and secure updated declarations of compliance from suppliers confirming no BPA or analogues in FCMs post-ban. You should also seek to phase out legacy stock in line with the regulation’s transitional periods.

Rest of the UK position

For Great Britain, the Food Standards Agency proposed a similar ban, which was under consultation until December 2025. If proposed legislation is passed, it should ensure consistency across the UK market and align GB with EU regulations. Until then, BPA remains authorised in plastics (other than in infant feeding articles) in Great Britain, with a specific migration limit of 0.05 mg/kg.

The FSA's Food Contact Materials Team can provide more information about the safety of BPA used in the food industry. You can contact them by email at FCM-BPA@food.gov.uk.

Cling film is safe to use as long as you use it correctly, for the intended food type and temperature, and in line with the manufacturer’s instructions. But not all types of cling film are suitable for all uses.

Cling film regulation

Cling film (both PVC and PE types) is regulated as a food contact material under EU regulation enforced in Northern Ireland through the Materials and Articles in Contact with Food Regulations (Northern Ireland) 2012.

The regulations set overall migration limits for substances migrating into food, and tightly controlled specific migration limits for additives and plasticisers. These limits ensure no harmful migration occurs under intended use.

Businesses should demonstrate due diligence by securing supplier declarations of compliance with migration limits, and keep records of these for inspections where necessary.

Safe usage rules for cling film

To prevent chemical migration from cling film and protect the quality and taste of food, it is important to:

• not use cling film where it could melt into the food - eg in ovens or on cooker hobs
• not allow cling film to touch the food when re-heating or cooking in a microwave
• not use cling film in contact with high fat foods (unless suitable for this purpose)

High fat foods include:

• some types of cheese
• raw meats with a layer of fat
• fried meats
• pastry products
• cakes with butter icing or chocolate coatings

Improper use of cling film increases the risk of plasticisers migrating above safe limits.

Phthalates are plasticisers used to increase the flexibility and durability of plastics like PVC. They are found in many household items and throughout the food industry in things like cling film, processing equipment such as gloves and conveyor belts, sealants, and some food packaging. They can even transfer from contaminated water or soil into food.

Phthalates can leach from plastics into food, leading to excessive exposure and posing risks to endocrine and reproductive health.

Health risks associated with phthalates in food

Phthalates take a long time to break down in the environment and appear at low levels in some foods. Research shows that some phthalates can disrupt endocrine health and affect animal hormones and livers, which is why authorities impose tight migration controls to prevent unsafe transfer from food contact materials into food. No conclusive evidence shows these levels have a harmful effect on humans.

Safe limits for phthalates in food

Phthalates are strictly regulated under EU regulation, including the plastics regulation, for materials intended to come into contact with food. This is enforced in Northern Ireland through the Materials and Articles in Contact with Food Regulations (Northern Ireland) 2012.

Generally, phthalates can be used in materials that do not come into contact with fatty foods or foods meant for infants or young children. The regulations set maximum limits on phthalate migration into food, restricting their use in certain materials (like plastics), and requiring safety assessments.

The European Food Safety Authority sets Tolerable Daily Intakes (TDIs) for phthalates, the amount of phthalates in food or drinking water that people can safely consume without harm. The European Commission sets legal limits for how much can be transferred from packaging to food. These limits were updated and significantly reduced in July 2023 by Commission Regulation (EU) 2023/1442.

Northern Ireland regulations for phthalates in food

Due to the Windsor Framework, Northern Ireland continues to follow many EU rules regarding chemicals and food safety, including the rules on phthalates. This means that food contact materials placed on the NI market must comply with phthalate migration limits set by EU authorities.

Plastics are widely used in food packaging because they extend shelf life, cut food waste, enable lightweight transport, and protect against contamination. However, plastics from food packaging can migrate into food, exposing consumers to contaminants.

Not all types of plastic are food safe. Some may contain chemicals like phthalates that are more likely to leech into food, rendering them unsafe.

Safety of plastic food packaging 

For a plastic to be food safe, it must be authorised for food contact by government regulation and legislation. In Great Britain, the Food Standards Agency (FSA) is the regulatory body that carries out food contact materials authorisations and sets the standards for packaging suppliers and manufacturers to follow. These standards ensure that plastics used in food packaging have been tested and found to be safe.

Regulating food contact plastics in Northern Ireland

Under the Windsor Framework arrangements, EU rules on the use and authorisation of plastics in food packaging apply in Northern Ireland, enforced by the Materials and Articles in Contact with Food Regulations.

The regulations set an overall migration limit for all food contact plastics and establish:

• 'positive lists' of monomers and starting substances permitted in FCMs
• a list of plastic and production aids for use in food contact plastics
• time and migration limits on using each specific authorised substance

The regulations also allow the use of permitted food additives in the manufacture of food contact plastics. This applies so long as they don't affect the food or exceed legal limits for both plastic and food additives.

Authorisation for food contact plastics in Northern Ireland

If a business wants to use a new substance in food packaging or other food contact materials, it must first prepare a technical file (dossier) using the European Food Safety Authority's (EFSA) guidance, explaining how the substance or recycling process will be used and why it is safe. The business then sends this dossier to the relevant authority in an EU Member State, using the national contact details provided by the European Commission. That authority passes the dossier to EFSA, which checks it is complete and then assesses the safety of the substance or process for its intended use. 

If EFSA's opinion is positive, the European Commission and Member States can authorise the substance and add it to the EU list of permitted substances for food contact materials. For recycled plastics, a similar system is used, but the authorisation covers the recycling process itself rather than individual substances.