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Food-contact guide · US FDA

21 CFR 177: is this polymer cleared for this use?

FDA asks whether every substance that may migrate is authorised for your use. A Part 177 listing, GRAS, prior sanction, threshold exemption or FCN can each be the answer.

4 min readFor quality, regulatory and technical leads at resin, masterbatch and converted-polymer manufacturers
Receiving colleague in hairnet, mask and coat checking an incoming drum on a tablet while a colleague in hi-vis works nearby

In Short

  1. 1Every migrating substance needs a route.
  2. 2An FCN covers only the notifier's substance.
  3. 3Listings carry limits on food, temperature and use.
Free guide24 pages · Online & printable · 2 worksheets · 10 primary sources · opens online

The Packaging & Food-Contact Materials Guide

Every roll traced to its film, ink and adhesive lots.

What's inside
  • Which rules apply
  • Evidence for the use
  • Hold, decide, trace
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We ask for your name and email so we can handle this request. The full guide then opens on this site, ready to translate, print or save. Privacy policy. Practical orientation, not legal advice; your quality unit decides which rules apply.

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The Packaging & Food-Contact Materials Guide

Every roll traced to its film, ink and adhesive lots.

QualityTraceabilityPerformance
Contents
  1. Five ways a substance can be authorised
  2. An FCN belongs to one manufacturer
  3. Read the whole listing
  4. Threshold of Regulation
  5. Keep evidence tied to each revision
  6. Questions
Contents
  1. Five ways a substance can be authorised
  2. An FCN belongs to one manufacturer
  3. Read the whole listing
  4. Threshold of Regulation
  5. Keep evidence tied to each revision
  6. Questions

FDA judges a food-contact material by the status of each substance that may migrate from it into food. 21 CFR Part 177 lists polymers cleared for food contact, each with conditions. Other routes are GRAS, prior sanction, a threshold of regulation exemption or an effective food contact notification (FCN). Sources checked 3 Oct 2026.

01

Five ways a substance can be authorised

FDA's page on determining the regulatory status of food contact components lists them: a regulation in 21 CFR (the indirect additive parts 174 to 178, including Part 177 for polymers), GRAS status, a prior sanction, a threshold of regulation exemption, or an effective FCN. The status of the finished material depends on every substance reasonably expected to migrate, not just the base resin.

Which route covers this substance?

Pick a route to see what to keep on file.

Regulation Listing
  • Identity, specifications and conditions of use.
Notifier-Specific
  • Confirm the substance comes from the named notifier.
21 CFR 170.39 exemption
  • Granted by FDA for a stated use.
Basis and Scope
  • Keep the basis and the use it covers.
Your regulatory team decides the status.
02

An FCN belongs to one manufacturer

Under 21 CFR 170.100, an FCN is effective only for the food contact substance made by the manufacturer or supplier named in it, for the stated intended use. Matching another firm's chemistry does not carry their FCN across.

More on an FCN belongs to one manufacturer

If your supplier relies on an FCN, confirm the resin comes from the notifier.

03

Read the whole listing

FDA suggests reading each authorisation in three parts: the identity of the substance, its specifications such as purity or physical properties, and the limits on conditions of use. A Part 177 listing can restrict food types, temperatures or extractives.

More on read the whole listing

21 CFR 174.5 adds that a substance must be of suitable purity and used at no more than the amount reasonably needed for its technical effect.

04

Threshold of Regulation

21 CFR 170.39 lets FDA exempt a specific use of a substance when, among other conditions, it is not a known carcinogen and use results in dietary concentration at or below 0.5 parts per billion. FDA grants the exemption for a stated use; check FDA's list rather than assuming it applies to your material.

05

Keep evidence tied to each revision

Customers often ask for a letter of guaranty or compliance statement. Keep each statement tied to the resin grade, supplier, revision and intended use.

Before you sign a compliance statement

0 of 5 in place
More on keep evidence tied to each revision

Review it when a formulation, supplier or use changes.

How V5 supports this

V5 keeps supplier declarations by revision, supplier qualification, change control and lot trace. It does not determine FDA status; your team does.

  • Approved SuppliersQualification status and documents per supplier.
  • Supplier PortalSuppliers upload declarations for review.
  • Document controlRevisions, approvals and review dates.
  • TraceabilityLink resin lots to finished lots.

Questions

Do we need our own FCN if our resin matches a notified product?

Yes, to market that substance for that use. 21 CFR 170.100 says an FCN is effective only for the substance from the manufacturer or supplier named in it.

Does a Part 177 listing cover the additives in our compound?

Not automatically. Each substance reasonably expected to migrate needs its own authorisation, and the polymer listing's own limits must also be met.

What is the threshold of regulation?

An FDA exemption under 21 CFR 170.39 for a specific use where dietary concentration is at or below 0.5 parts per billion, among other conditions.

Can V5 tell us whether a polymer is FDA-cleared?

No. V5 does not determine regulatory status. It keeps supplier declarations by revision, supplier qualification, change control and lot trace, so your team can show the evidence it relied on.

Industry
  • Packaging & Food-Contact Materials
  • Plastics & Resins

Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.

Keep reading

  • Food-Contact Materials in the EU and US: One Evidence File, Two Systems
  • EU 10/2011 Plastics Food Contact: Union List, Migration Limits and the Declaration of Compliance
  • EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 Readiness
  • FCM Migration Testing Readiness Guide (EU 10/2011 & FDA)
  • Bisphenols and Phthalates in Plastics: EU 2024/3190, FDA Abandoned Uses and CPSC Limits
  • Recycled Plastics for Food Contact: EU 2022/1616 and FDA's Recycling Guidance
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Page version 1.4· Last revised 3 Oct 2026