Food and Beverage Packaging Planning Guide

Separate the Food-Contact Layer From the Outer Package

Food and beverage packaging often involves at least two layers. The first is an immediate container or liner that touches the product. The second is a secondary package, such as a folding carton, sleeve or label, that carries branding and required statements. The immediate container might be a bottle, jar, pouch, can or liner, and many custom packaging projects focus on the secondary layer.

FDA describes food contact substances as including packaging and its components, as well as substances applied to packaging surfaces such as adhesives, colorants and certain antimicrobials and antioxidants. Under federal law, a food contact substance that is a food additive must be authorized for that use before it is marketed in the United States. Ask your material supplier and, where relevant, your converter how that question applies to each material. We recommend documenting what each layer is made of and who supplied it, because co-packers, retailers or auditors may ask for that paperwork.

When you brief a packaging partner like Teal, be explicit about which surfaces touch food and which do not. A printed folding carton holding a sealed pouch is a different project from a printed liner or direct-contact wrap, and the material and ink conversation changes accordingly.

• List every layer in the package and mark which ones contact food.
• Ask each material supplier for documentation supporting the intended food-contact use.
• Keep a simple specification sheet per SKU: layer, material, supplier, contact or non-contact.

Recycled Plastic in Direct Food Contact

Post-consumer recycled (PCR) plastic is popular for sustainability goals, but when it touches food the safety questions are specific. FDA's stated concerns are that contaminants from the PCR material may appear in the final food-contact product, that PCR material not regulated for food-contact use may be incorporated, and that adjuvants in the PCR plastic may not comply with food-contact regulations.

FDA considers each proposed use of recycled plastic case by case and issues informal advice on whether a recycling process is expected to produce PCR plastic of suitable purity for the intended application. The agency evaluates the source of the PCR material, the recycling process, test data on contaminant removal, and the proposed conditions of use such as food type, temperature, contact duration and whether the article is single-use or repeated-use. Notably, FDA no longer evaluates tertiary recycling processes for PCR PET or PEN individually, having determined those processes produce material of suitable purity for food-contact use.

Practically, this means you should not treat a generic 'food grade PCR' claim as sufficient. Ask your supplier which resin, which process and which conditions of use their documentation covers, and match that to your actual product: a cold, dry, short-contact use is a different case from hot-fill or fatty foods.

• Confirm resin type, recycling process and source controls in writing.
• Match documented conditions of use to your real product, temperature and contact time.
• For PCR PET made through tertiary recycling, note that FDA no longer issues individual process opinions for that category.

Label Content Planning for Foods

FDA's Food Labeling Guide summarizes required statements for food labels under the FD&C Act and the Fair Packaging and Labeling Act, and it states plainly that FDA does not pre-approve labels for food products. Using a reviewer or printer does not replace the food business's responsibility to understand applicable requirements. Identify responsibilities among the brand, manufacturer, packer, distributor and importer as applicable, and use a review workflow rather than a one-pass sign-off.

Typical elements to plan for include the statement of identity, net quantity of contents, ingredient list, nutrition labeling where required, and the name and address of the manufacturer, packer or distributor. The Nutrition Labeling and Education Act requires most foods to bear nutrition labeling and sets specific requirements for nutrient content claims and certain health messages. Regulations change, and FDA places responsibility on the food industry to stay current, with new rules published in the Federal Register before their effective dates.

Layout matters as much as content. Required information needs to fit the panels you have, so we recommend mapping which statement goes on which panel before finalizing dielines. If your product may be a dietary supplement rather than a conventional food, a different labeling framework may apply, so classify the product first and confirm the applicable rules.

• Classify the product: conventional food, dietary supplement, or something regulated elsewhere.
• Map required statements to specific panels early in structural design.
• Verify current requirements against the regulations rather than a template, since rules change.

A Worked Layout Check for a Folding Carton

Here is a hypothetical, simplified geometry exercise to show how panel budgeting works. Suppose you are planning a rectangular folding carton for a snack product, and the carton face is 150 mm wide by 210 mm tall. You want to check whether the front panel can hold a logo, a product name, a flavor descriptor and a net quantity statement without crowding.

Assume you allocate 40 mm at the top for the logo, 30 mm for the product name, 12 mm for a flavor descriptor, and 15 mm at the bottom for the net quantity statement. Add those: 40 plus 30 plus 12 plus 15 equals 97 mm of content height. Subtract from 210 to get 113 mm, and if you want 12 mm of breathing space between each of the four elements, that is three gaps of 12 mm, or 36 mm total. 97 plus 36 equals 133 mm, which still fits within 210 mm with 77 mm to spare for imagery or whitespace.

Now reverse the check for a smaller carton. If the face were 120 mm tall, the same 133 mm of content would not fit. You would need to reduce element heights or gaps, or drop optional elements such as the descriptor. Do not simply relocate the net quantity statement, because its placement and minimum type size are regulated. This arithmetic is a hypothetical planning estimate only. It omits safe-area margins, flaps, glue tabs and fold geometry. Actual type sizes and placement rules must be verified against current regulations and your converter's dieline.

Choosing a Structure and Material Combination

Structure choice follows the product, the channel and the filling process. For a co-packed pouch, confirm early who owns the printed film specification, since co-packers often have equipment requirements. A rigid box or folding carton can support retail shelf presence and offers flat panels for required statements. Sleeves and labels can work when the immediate container already exists.

The following table is a planning aid, not a compliance or performance determination. Validate any structural choice with drop, transit or shelf testing appropriate to your product and distribution before committing to a production run.

Review Workflow Before You Commit Artwork

Because FDA does not pre-approve food labels, we recommend an internal review with named decision points and qualified external review where appropriate. Confirm whether other authorities or channel partners have review requirements for your product. This checklist is Teal's editorial planning framework for organizing the work; the cited FDA sources cover only the specific underlying principles noted above, not this workflow itself.

• Classify the product and confirm which labeling framework applies.
• Confirm every food-contact layer and collect supplier documentation for the intended use.
• Draft the required statements and map each to a panel on the dieline.
• Check claims language, including nutrient content and health claims, against current regulations.
• Run a fresh arithmetic panel-budget check after any dieline change.
• Get a proof and review it against the panel map, not just the design.
• Have a named person sign off on content accuracy before production.

Scope Limits

This guide covers planning workflow only. It does not determine compliance for any specific product, does not establish safety thresholds, shelf life or temperature guarantees, and does not substitute for review of the current regulations in Title 21 of the CFR or advice from a qualified regulatory consultant. Teal does not certify products to CPSC, FDA or ISTA standards. Channel-specific requirements, such as retailer or marketplace labeling rules, should be confirmed in your own agreements, since those terms vary and are not resolved by the sources reviewed here.

Questions about food and beverage packaging planning