Verify food-contact status, compostability claims, certificate scope, restricted-substance evidence, responsible fibre sourcing and lot-level quality records before approving a foodservice packaging program.
Buyer Review Scope
A compliant compostable packaging producer supplies product-specific evidence for food-contact safety, compostability, restricted substances, traceability and responsible sourcing. The compliance file should match the exact SKU, material structure, intended food use, destination market and certification claim, allowing procurement and QA teams to verify evidence before sample, artwork and purchase-order approval.
Evidence Before Claims
A certificate folder is useful only when the documents can be connected to the product being purchased. Every report, declaration and certificate should identify what was assessed, which market and use conditions it covers, and whether the evidence remains valid for the supplied SKU.
01
The document must identify the exact product code, dimensions, unit weight, material, coating, colour, printing and attached components.
02
Food type, contact time, temperature, reheating, freezer use and direct-food-contact surfaces must match the regulatory or test basis.
03
The file must distinguish food-contact compliance, industrial or home compostability, FSC sourcing, PFAS requirements and other buyer claims.
04
Certificate status, report date, sample identity, approved formulation and notification obligations must remain controlled after approval.
What Is Not Enough?
Market-Matched Documentation
Food-contact regulations, compostability standards, certification schemes and responsible-sourcing claims prove different things. The following matrix helps procurement teams define the correct document request before quotation, sample testing or purchase-order approval.
| Buyer Checklist Buyer Requirement | Verification Purpose What It Proves | Applicable Route Typical Regulatory or Standard Route | Document Check Evidence to Request | Verification Level Scope |
|---|---|---|---|---|
| 01 US Food-Contact Compliance | Whether each relevant component is authorised for its identity, intended application and conditions of use. | Applicable FDA authorisations, including relevant provisions within 21 CFR Parts 175–178, effective FCNs, TOR exemptions or another valid regulatory route. | Composition statement, regulatory declaration, supplier guarantees, intended-use conditions and applicable laboratory reports. | Component |
| 02 EU Food-Contact Compliance | Whether the finished food-contact article is suitable for the intended food, time and temperature without unacceptable transfer. | Regulation (EC) No 1935/2004, Regulation (EC) No 2023/2006, applicable harmonised material measures and relevant national requirements. | Compliance statement, migration or extractables testing where applicable, sensory assessment, composition data and traceability. | Finished SKU |
| 03 EU Industrial Compostability | Whether the complete packaging construction meets the applicable industrial-compostability assessment criteria. | EN 13432 with product certification such as DIN CERTCO, Seedling or OK compost INDUSTRIAL where applicable. | Certificate number, certificate holder, listed product, maximum thickness or weight, approved components and validity. | Complete Item |
| 04 North American BPI Certification | Whether the listed product satisfies BPI’s certification scheme and applicable ASTM compostability assessment route. | ASTM D6400 as BPI’s base standard, with optional ASTM D6868 or ASTM D8410 assessment for eligible product structures. | Searchable BPI product listing, company or certificate ID, listed SKU, product description, colour, thickness and mark authorisation. | Listed SKU |
| 05 EU PFAS Restrictions | Whether food-contact packaging is below applicable PFAS concentration thresholds for placement on the EU market. | Regulation (EU) 2025/40 thresholds applying from 12 August 2026: 25 ppb for an individual targeted PFAS, 250 ppb for the targeted PFAS sum and 50 ppm for total PFAS, subject to the Regulation’s conditions. | Formulation declaration, sample identity, targeted PFAS results, total fluorine or total PFAS evidence where required, test method, reporting limit and technical documentation. | Market Entry |
| 06 BPI Fluorine Requirements | Whether a product satisfies BPI’s separate fluorinated-chemical conditions for use of its certification claim. | No intentionally added fluorinated chemicals and a maximum of 100 ppm total organic fluorine under current BPI requirements. | Signed formulation statement, relevant SDS information and a report from a BPI-approved laboratory identifying the tested item. | Certification |
| 07 FSC-Certified Fibre Claim | Whether certified forest-based material has remained controlled through purchasing, processing, labelling and sale. | FSC Chain of Custody certification, transaction claims and FSC trademark requirements. | Current certificate, licence code, supplier status, product-group scope, invoice claim and approved label artwork. | Transaction |
| 08 China Compostability Testing | The ultimate aerobic biodegradability of a material under controlled composting test conditions. | GB/T 19277.1-2025, effective from 1 November 2025, using carbon-dioxide evolution under controlled composting conditions. | Laboratory report, test specimen, material identity, test conditions and any additional finished-product or labelling evidence required for the claim. | Test Method |
From Requirement to Evidence
The compliance review begins with the product specification and market, not with a preassembled folder of company certificates. This reduces the risk of presenting a valid document that does not actually cover the supplied material, structure or use condition.
01
Confirm the SKU, material structure, food application, contact temperature, destination country, required claim, annual volume, packaging configuration and buyer-specific restricted-substance list.
02
Check the substrate, coating, additives, inks, adhesives and attachments against the intended food-contact use and any compostability, PFAS or sourcing claim.
03
Match the sample identity, food simulant or test medium, contact time, temperature, functional use and reporting limits to the product’s foreseeable operating environment.
04
Organise specifications, declarations, reports, certificates, database listings, artwork permissions and supplier evidence around the approved SKU rather than the company name alone.
05
Link the approved specification to production and shipment records, and require review when the material supplier, formulation, coating, printing, dimension or manufacturing process changes.
Beyond the Certification Logo
A recognised logo does not automatically prove that every product sold by the certificate holder is certified. Procurement teams should verify the listed item, certificate scope and report sample before accepting a claim for a purchase order.
High-Risk Evidence
Approval Evidence
A logo, colour, coating, label or packaging change may affect the certified scope or mark approval. Certification-mark placement should therefore be reviewed as part of the controlled artwork process.
Material-Specific Food-Contact Evidence
A generic “food-grade” declaration cannot cover every foodservice packaging material. The required evidence must reflect the substrate, additives, coating, printing, adhesives, intended food type, contact temperature, duration of use and destination market of the finished SKU.
01
Covers bagasse tableware, paper cups, paper bowls, food boxes, buckets, trays, paper bags, paper straws and other fiber-based articles intended for food contact.
02
Covers PET cold cups, PP cups, plastic lids, plastic straws and paper products containing plastic coatings, laminated barriers or polymer sealing layers.
03
Covers disposable forks, spoons, knives, sporks, cutlery sets and bamboo plates, bowls, trays or cutlery. The exact material and construction must be identified before selecting the compliance route.
04
Cross-category components must be assessed together with the base material because they can change food-contact, restricted-substance and compostability compliance.
Bamboo material distinction: buyers should verify whether a product is made from solid bamboo or consists of plastic containing bamboo powder or another plant-based filler. These constructions do not follow the same EU compliance route.
Paper hygiene product scope: paper napkins or kitchen paper intended for food contact should be reviewed for that use. Facial tissue, toilet paper and pocket tissues should follow their applicable product-safety and market documentation rather than being presented as food-contact packaging.
Molded-Fiber Validation Example
“Food-grade bagasse” is not a complete specification. The compliance review must consider the fibre, processing aids, bleaching treatment, barrier chemistry, inks, adhesives and actual food-contact conditions of the finished article.
Reports and declarations should be checked against the supplied product code, unit weight, dimensions, coating structure, intended food type, maximum contact temperature and duration of use.
Fibre and additive composition
Bleaching or colour-treatment information
Barrier and coating chemistry
Ink and adhesive information
Food type and contact duration
Maximum contact temperature
Migration or extractables reports
Sensory assessment where relevant
PFAS or fluorine evidence
Lot and material traceability
Molded-Fiber Validation Example
The examples below show how food type, temperature, contact duration and barrier treatment can change the validation plan for a molded-fiber SKU.
| Application Profile Intended Application | Buyer Input Conditions to Define | Validation Planning Typical Validation Considerations |
|---|---|---|
| 01 Dry or Short-Contact Food | Food type, direct-contact side, storage period and ambient temperature. | Composition review, odour or taste transfer, visual cleanliness, physical integrity and applicable chemical restrictions. |
| 02 Hot and Moist Food | Maximum temperature, contact duration, humidity and lid or closure conditions. | Heat resistance, water resistance, deformation, fibre transfer, sensory performance and applicable migration or extractables testing. |
| 03 Oily or Greasy Food | Fat content, serving temperature, holding time and barrier treatment. | Grease resistance, barrier composition, transfer testing, PFAS evidence and performance after prolonged contact. |
| 04 Microwave or Reheating Use | Heating time, power, food type, starting temperature and venting conditions. | Structural stability, hot spots, leakage, deformation, odour, component suitability and clearly defined use limitations. |
| 05 Chilled or Frozen Storage | Storage temperature, duration, food moisture, condensation and thawing conditions. | Dimensional stability, brittleness, moisture resistance, leakage and performance after temperature transition. |
Claim and Mark Control
“Biodegradable,” “industrially compostable,” “home compostable” and “certified compostable” are not interchangeable claims. The supporting evidence and permitted certification mark must match the disposal environment, market and finished product.
Evidence Layer 01
A standard defines test methods and acceptance criteria. A test report should identify the specimen, method, conditions and results.
Examples: EN 13432, ASTM D6400, ASTM D6868
Evidence Layer 02
A certification body evaluates the product and lists the approved construction within a controlled certificate or searchable database.
Examples: BPI, DIN CERTCO, Seedling, OK compost
Evidence Layer 03
The wording, logo, certificate number and disposal instruction must follow the certification owner’s mark-use and sublicense requirements.
Controlled during artwork approval
The base fibre or resin may be supported by valid test evidence while the finished item remains outside the certificate scope. Printing inks, adhesives, coatings, labels, lids and other attached components should therefore be reviewed before a compostability mark is applied.
Verifiable Sourcing Claims
Responsible sourcing should be supported by traceable purchasing, transaction and material evidence. The page therefore focuses on verifiable records rather than broad environmental promises.
An FSC-certified supplier should be able to connect the fibre claim to an active certificate, eligible product group, controlled supplier, transaction document and approved trademark use.
Material-origin documentation should identify the substrate, supplier, grade, recycled or virgin content where claimed, production location and approved substitution controls.
“PFAS-free” can refer to formulation controls, certification requirements, targeted PFAS analysis, total organic fluorine or broader total-fluorine evidence. The accepted definition, method and reporting limit must be agreed before testing.
No-intentionally-added declaration, formulation review and relevant raw-material or SDS information.
Product code, material, coating, print, colour, production date and sample photograph where available.
Targeted PFAS, total organic fluorine or other buyer-specified method with a defined reporting limit.
Reassessment when the paper, fibre, barrier treatment, coating, ink, adhesive or supplier changes.
Do not treat the BPI fluorine limit as automatic proof of EU PPWR compliance. They are separate schemes with different scope, terminology, thresholds and documentation requirements.
Evidence Behind the Shipment
The purpose of the quality system on this page is not to repeat the complete factory introduction. It is to show how approved specifications and compliance evidence remain connected to the sample, production lot and shipment.
Xcellink EcoPack operates under a BRCGS-supported quality-control framework covering incoming materials, production controls, inspection, traceability, non-conformance management and corrective action. Certificate scope and validity should be confirmed from the current certificate copy.
01
Compare the buyer specification, approved material, report sample, certificate scope and required declarations before production approval.
02
Confirm dimensions, unit weight, appearance, printing, closing, stacking, resistance and other agreed acceptance criteria against the approved sample.
03
Verify the manufactured SKU, packing configuration, batch identification, inspection records and required shipment documents before release.
Manufacturing Context
These figures are retained only as supporting context. Full factory, production and team information belongs on the About page.
Automated Lines
Self-Developed Machines
Annual Output
Approx. Annual Loading
Procurement Approval Tool
Use this checklist to identify missing evidence before approving a sample, private-label artwork or purchase order. Not every document applies to every SKU, but every claim should have a clear and verifiable evidence route.
Before Sampling
Before PO Approval
Before Shipment
Include the intended market, product use, required claim and document list in the initial RFQ. This allows missing evidence to be identified before tooling, testing, printing or mass production begins.
Regulatory References
Key official sources used to structure this compliance guidance.
Procurement Questions
Answers for buyers planning multi-category foodservice packaging, private-label programs and repeat international supply.
A qualified supplier must provide separate evidence for food-contact compliance and industrial compostability.
For the United States, the file should identify the regulatory status of each relevant component for the intended food-contact use and conditions. FDA does not issue a universal approval covering an entire packaging factory.
For EN 13432, the supplier should provide product-level testing and preferably valid third-party certification covering the finished construction, including applicable coatings, inks, adhesives and attached components.
The document package should normally include:
Each document should be checked against the actual product code, material, construction and market.
There is no universal test package for every bagasse product. The test plan should reflect the fibre, additives, bleaching process, barrier coating, ink, food type, contact time and temperature.
Depending on the product and market, validation may include composition review, migration or extractables testing, restricted-substance testing, heavy metals, sensory assessment, oil and water resistance, heat performance, PFAS or fluorine testing and microwave or freezer-use checks.
Search the BPI online product catalogue and compare the listed company, product code, description, colour, thickness or unit weight and other identifying information with the quotation and approved specification.
The supplier should also confirm whether printing, labels, coatings, adhesives or private-label packaging are included in the certified or sublicensed construction.
No. FSC Chain of Custody evidence supports responsible sourcing and traceability of forest-based materials. It does not by itself prove food-contact compliance, compostability, recyclability or PFAS status.
Each additional claim requires its own appropriate regulatory, laboratory or certification evidence.
The file should identify the applicable market requirement, the definition being used, the tested specimen, the formulation statement, the laboratory method, the reporting limit and the production or material scope covered.
Buyers should not assume that a result meeting one certification scheme automatically satisfies a separate regulation in another market.
Procurement and QA Review
Submit the target SKU, material, food application, contact temperature, destination country, estimated annual volume and required certification or restricted-substance evidence.
We will organise the available documents around the proposed product, identify evidence gaps and clarify which items require testing, certificate verification or market-specific confirmation before samples and bulk quotations are finalised.
