Sourcing packaging materials for food exporters: food-contact compliance, lead times and MOQs

For a food exporter, packaging is part of the product. A pouch, can, jar or carton that does not meet the destination's food-contact rules can stop a shipment as surely as a pesticide residue problem. Packaging also sets the pace of a launch: printed materials often have longer lead times and higher minimum order quantities (MOQs) than the food itself.

This guide covers what compliance documents to ask for, the main rule changes in 2026, and how to plan lead times and MOQs. It reflects the position at the time of writing, October 2026.

The principle: the packaging must be safe for the food and the market

Most markets apply the same basic test. Packaging must not transfer substances into food in quantities that could endanger health or change the food unacceptably. How that test is applied differs by market, so start by listing every destination you plan to sell in and the type of food: dry, fatty, acidic, alcoholic, frozen or heated in the pack. Migration testing depends on these conditions.

European Union

The EU framework Regulation (EC) No 1935/2004 applies to all food-contact materials. Plastics are covered in detail by Regulation (EU) No 10/2011, which sets a positive list of authorised substances, an overall migration limit of 10 milligrams per square decimetre of food-contact surface, and specific migration limits for individual substances. Every business in the chain except retail must have a written declaration of compliance, supported by test results and calculations that can be shown to the authorities on request.

Two changes in 2026 matter for exporters. First, Regulation (EU) 2024/3190 bans bisphenol A (BPA) and restricts other hazardous bisphenols in food-contact materials. The main transition period ended on 20 July 2026, with later deadlines (mostly January 2028) for example for certain fruit, vegetable and fish preserves and for metal packaging coated with BPA only on the outside. This affects can coatings, lids and closures in particular. Second, the Packaging and Packaging Waste Regulation (EU) 2025/40 has applied generally since 12 August 2026. From that date, food-contact packaging cannot be placed on the EU market if it contains PFAS above set limits: 25 parts per billion for any individual PFAS, 250 ppb for the sum of targeted PFAS, and 50 parts per million for total PFAS. There is no sell-through period for packaging first placed on the market after that date. PFAS have often been used for grease resistance in paper and board, so ask paper suppliers specifically about them.

United States

In the United States, a substance used in food-contact packaging must be authorised in one of several ways: listed in the indirect food additive regulations in 21 CFR Parts 174 to 179, generally recognised as safe (GRAS), covered by a prior sanction, exempt under the threshold of regulation, or covered by an effective Food Contact Substance Notification (FCN). An FCN covers only the named manufacturer's substance, so your converter must buy that substance from that manufacturer. Ask your supplier for a letter of guaranty that names the applicable regulation or FCN for each layer.

GCC markets

GCC Standardization Organization standards apply across the Gulf once adopted by each member state. GSO 839:2021 (Food packages, Part 1: General requirements) covers packages made of metal, glass, plastic, paper, board and other materials. For plastics, GSO 1863 sets a positive list and migration limits that, according to a 2019 Keller and Heckman analysis, largely mirror EU Regulation 10/2011. A packaging supplier that can show EU compliance therefore has a good starting point, but you should still confirm adoption and any national rules with the importer in each country.

Separately, the UAE banned the import, production and trade of a wider range of single-use plastic products from 1 January 2026 under Ministerial Decision No. 380 of 2022. The list includes plastic cups and lids, cutlery, plates, straws, stirrers and polystyrene food containers. Products made solely for export or re-export are exempt if clearly labelled. If you supply foodservice in the UAE, check your packaging against this list.

Documents to request from every packaging supplier

• Technical data sheet and full material specification, including each layer of a laminate and any inks, adhesives and coatings.
• Declaration of compliance (EU) or letter of guaranty (US) for the exact product and intended use: food type, temperature and time.
• Migration test reports from an accredited laboratory, with the food simulants and test conditions stated.
• Statement on BPA and other bisphenols for cans, closures and coatings.
• Statement and test results on PFAS for paper, board and moulded fibre.
• Certificate for the factory's hygiene or quality system, for example BRCGS Packaging Materials, FSSC 22000 or ISO 9001, verified with the certifier.
• Batch traceability: how each roll, carton or pallet can be traced to raw material lots.

Lead times and MOQs: plan backwards

Lead times and MOQs vary widely by material, printing method and supplier, so there are no standard figures. Ask each supplier to break the lead time into stages: artwork approval, cylinder or plate making, raw material supply, production, testing and transport. Digital printing usually allows shorter runs than gravure or offset printing but may cost more per unit. Stock items, such as plain jars or unprinted cartons, typically need lower MOQs than custom printed items.

Illustrative example only: an exporter launches a spice blend in printed stand-up pouches. The supplier quotes an MOQ of 50,000 pouches per design and five weeks from artwork approval to dispatch, plus three weeks of sea freight. If the exporter sells 8,000 pouches a month, one order covers more than six months of sales. That ties up cash and storage, and any label change would make stock obsolete. Options include fewer designs with a blank area for a variant sticker, digital printing for slower lines, or agreeing call-off deliveries from a larger order.

Questions to ask before you place the order

• What is the MOQ per design, per size and per colour, and what is the price at two or three quantity levels?
• Can you hold stock and deliver against call-offs?
• Which substances in this structure have migration limits, and have they been tested for our food and conditions?
• Will you notify us before changing any raw material, ink or adhesive supplier?
• What happens if a batch fails our incoming inspection or a customer's test?

Final checks

Keep compliance documents for each packaging item on file and review them whenever the destination, food or supplier changes. Food-contact rules are detailed and changing, so confirm specific requirements with a specialist laboratory, consultant or the importer in your target market.

Finding packaging suppliers on Nexus BYF

On Nexus BYF you can post a buy requirement for food packaging free of charge, stating the material, size, quantity and target markets, and compare any quotations you receive. You can browse free sell offers and company profiles, check whether a supplier holds the optional Verified badge, and use paid membership to contact suppliers directly and request their compliance documents early.