Food-Grade Materials: FDA Compliance Requirements Explained

“Is this material food grade?”

We hear this question daily, and the answer is rarely simple. “Food grade” isn’t a single certification—it’s a complex regulatory framework involving FDA regulations, NSF standards, and application-specific requirements. Getting it wrong can mean failed audits, product recalls, or worse.

This guide clarifies what food-grade compliance actually requires and which materials meet those requirements.

What “Food Grade” Actually Means

There is no universal “food grade” certification that applies to all materials in all applications. Instead, compliance depends on the interplay of several factors. First, the material composition matters—what the material is made of at a chemical level determines its baseline eligibility. Second, the application context is critical: whether the material makes direct contact with food, indirect contact, or handles specific food types changes the requirements entirely. Third, the conditions of use play a major role, including operating temperature, how long the material contacts food, and whether that food is acidic, fatty, or aqueous. Finally, the applicable regulatory framework varies by jurisdiction and industry—FDA, USDA, NSF, 3-A, and EU regulations each have their own requirements.

A material can be FDA compliant for cold beverages but prohibited for hot fatty foods. Context matters.

FDA Regulations: The Foundation

The FDA regulates food contact materials under 21 CFR (Code of Federal Regulations). Understanding the key sections helps you navigate compliance requirements.

21 CFR 177 covers Indirect Food Additives: Polymers. This section lists polymers approved for food contact applications, specifying limitations on which types of food they can contact (aqueous, acidic, fatty, or alcoholic), the acceptable temperature ranges, how long contact can occur, and maximum extraction limits.

21 CFR 178 addresses Indirect Food Additives: Adjuvants, covering additives and processing aids used in food contact materials.

21 CFR 182/184 establishes Generally Recognized as Safe (GRAS) status for materials with a long history of safe use.

When a material is FDA compliant, it means that material appears on FDA-approved lists for the intended application and any specified limitations are respected in use. However, FDA compliance does not mean the FDA has tested or certified the specific material you’re using, nor does it mean the material is approved for all food applications. Compliance still requires proper documentation and verification—it’s not automatic or universal.

FDA-Compliant Plastics

The following plastics have FDA-compliant grades available. Specific formulations matter significantly—the base polymer may be approved while certain colorants or additives render a particular grade non-compliant.

Commonly Specified FDA Plastics

Material	FDA Reference	Typical Limitations
UHMW	21 CFR 177.1520	General food contact
HDPE	21 CFR 177.1520	General food contact
Polypropylene	21 CFR 177.1520	General food contact
Acetal/Delrin	21 CFR 177.2470	Limited fatty food contact
Nylon 6/6	21 CFR 177.1500	Some fatty food limitations
PTFE/Teflon	21 CFR 177.1550	High-temperature approved
PEEK	21 CFR 177.2415	High-temperature approved
Polycarbonate	21 CFR 177.1580	Non-alcoholic applications

Important Caveats

Color matters more than many buyers realize. Only natural, white, or specifically FDA-approved colors qualify—random colored materials are typically not FDA compliant. The pigments and dyes used in industrial plastics often contain compounds not approved for food contact.

Grade specification is equally critical. “FDA compliant UHMW” refers to material specifically formulated for food contact applications, which differs from standard industrial UHMW. Always specify FDA grades explicitly when ordering.

Documentation closes the loop. Suppliers should provide compliance letters confirming the specific material meets FDA requirements for your application. Without paperwork, you have no audit trail.

FDA-Compliant Metals

Metals are generally more straightforward than plastics for food contact applications. The primary concerns center on three areas: toxic metals like lead and cadmium must remain below regulatory limits, the material must resist corrosion to prevent contamination of food products, and surface finish must be smooth enough to allow proper cleaning—typically Ra 32 microinches or better.

Commonly Approved Metals

Stainless Steel remains the standard for food-grade metal applications. Both 304 and 316 stainless are approved under FDA regulations and NSF standards. The 316 grade is preferred in environments where chlorides (salt) are present, as its molybdenum content provides superior pitting resistance.

Aluminum is generally acceptable for food contact when anodized or used in non-acidic applications. Raw aluminum can react with acidic foods, so the application matters.

Brass and Bronze have limited approval. Lead-free grades may be acceptable for specific applications, but you must verify the specific alloy’s compliance for your intended use.

Certain materials should be avoided entirely. Galvanized steel poses problems because its zinc coating can contaminate acidic foods. Leaded brass and bronze are prohibited due to lead content. Uncoated carbon steel raises corrosion concerns that make it unsuitable for food contact. Cadmium-plated materials are toxic and should never contact food.

NSF Certification: Beyond FDA

NSF International provides third-party certification that extends beyond basic FDA compliance. When a material carries NSF certification, it means independent laboratory testing has confirmed the material meets standards, manufacturing processes have been audited, ongoing surveillance ensures continued compliance, and the product appears in NSF’s publicly searchable database.

Key NSF Standards

NSF/ANSI 51 establishes requirements for Food Equipment Materials. This is the primary standard for food contact materials and equipment, covering materials selection, design principles, construction methods, and cleanability requirements.

NSF/ANSI 61 governs Drinking Water System Components, applying to materials that contact potable water. This standard includes extraction testing for contaminants that might leach into water supplies.

NSF/ANSI 14 addresses Plastics Piping System Components for use in potable water systems.

When NSF Is Required

NSF certification becomes necessary in several common scenarios. Major food processors often require NSF-listed materials as a baseline procurement standard. Health department inspections may specifically require NSF certification for equipment. Food equipment manufacturers typically specify NSF materials in their bills of materials. Customer specifications increasingly mandate third-party certification as a quality assurance measure.

The key difference between FDA and NSF is verification: FDA compliance is self-declared by the manufacturer, while NSF certification is independently verified through testing and audits.

3-A Sanitary Standards

The 3-A Sanitary Standards apply specifically to dairy and food equipment where cleanability is paramount. These standards address material composition requirements, surface finish specifications (Ra 32 microinches maximum), design criteria that enable effective cleaning, and the elimination of crevices, pockets, or dead spots where contamination could accumulate.

3-A standards are referenced by USDA for meat and poultry processing equipment, making them relevant beyond dairy applications.

Application-Based Requirements

Direct vs. Indirect Contact

The distinction between direct and indirect food contact fundamentally changes material requirements. Direct contact means the material physically touches food and must meet FDA requirements specific to that food type and the conditions of contact. Indirect contact describes materials that are near food but don’t touch it—guards, frames, structural members, and non-contact surfaces. Requirements for indirect contact are less stringent, though you must still consider contamination potential from cleaning chemicals, condensation, or accidental contact.

Food Type Categories

FDA classifies foods into categories that affect material requirements. Understanding these categories helps you specify appropriate materials.

Category	Examples	Concern
Aqueous	Water, juices, beverages	Low
Acidic	Citrus, tomatoes, vinegar	Extraction/corrosion
Fatty	Oils, butter, meat	Extraction into fats
Alcoholic	Beer, wine, spirits	Extraction
Dry	Grains, powders	Minimal

Materials approved for aqueous foods may not be approved for fatty foods because fats can extract certain compounds more aggressively than water-based products. Always verify approval for the specific food category you’re handling.

Temperature Considerations

Material approval is temperature-dependent. A plastic approved for room-temperature contact may lose its compliance status for hot-fill applications or cooking temperatures. Higher temperatures accelerate extraction and can cause materials to break down or release compounds that wouldn’t migrate at lower temperatures. Always verify approval at your maximum operating temperature, not just your typical operating conditions.

Practical Compliance Steps

Achieving and maintaining compliance requires a systematic approach. Start by identifying your requirements: determine which regulatory framework applies (FDA, USDA, NSF, or customer specifications), characterize the type of food contact involved, and document the conditions including temperature, duration, and cleaning chemicals used.

With requirements defined, select compliant materials by choosing options with established compliance for your specific application. Specify FDA-compliant or NSF-listed grades explicitly in purchase orders and avoid colored materials unless they’re specifically approved for food contact.

Obtaining proper documentation is essential. Request FDA compliance letters from material suppliers, obtain Certificates of Compliance for each material lot, keep NSF listing verification on file when required, and maintain organized documentation for audits.

Surface finish verification ensures cleanability. Specify surface finish on engineering drawings (Ra 32 microinches is typical for food contact), avoid designs with crevices, threads, or features that trap contamination, and review designs specifically for cleanability before production.

Traceability ties everything together. Document material lot numbers, keep supplier certifications organized and accessible, and establish receiving verification procedures that confirm incoming materials match specifications.

Common Mistakes

Many compliance failures stem from incorrect assumptions. Assuming all plastic is food-safe is perhaps the most common error—standard industrial plastics are not FDA compliant, and you must specify FDA grades explicitly.

Ignoring the application leads to problems when a material that’s compliant for water turns out to be non-compliant for fatty foods or elevated temperatures. Each application requires its own verification.

Accepting verbal assurance without documentation means nothing in an audit. “It’s food grade” from a salesperson provides no legal protection—always obtain written compliance documentation.

Overlooking cleaning chemicals creates hidden failures. Materials must resist not only the food products they contact but also the cleaning and sanitizing chemicals used in daily operations. A material that handles food well but degrades under caustic cleaning solutions will fail in service.

Specifying inappropriate surface finishes undermines even the best material selection. Rough surfaces harbor bacteria and prevent effective sanitization. Food contact surfaces require finishes smooth enough to clean properly.

Working With NextGen Components

We stock FDA-compliant grades of common food processing plastics and can source specialty materials for specific requirements. Every food-grade material we supply includes material identification and lot traceability, FDA compliance documentation, Certificates of Compliance, and NSF listing verification where applicable.

Need food-grade materials or help navigating compliance requirements? Contact our team with your application details.