The global sustainable food packaging market is predicted to reach USD 667.06 billion by 2035 at a 11.1% CAGR during the forecast period, 2026 to 2035. The push for sustainable and post-consumer recycled (PCR) materials is rapidly reshaping the food-contact landscape and the corresponding safety and regulatory compliance aspect.
We spoke to Kari Barnes, regulatory standards manager at TraceGains, to understand the importance of food-contact substance testing. Kari unpacks the most common food-contact notification (FCN) pitfalls and the real-world challenges manufacturers face in the current sustainability-versus-food safety conversation.
1. What do manufacturers commonly get wrong when preparing an FCN submission?
The most common problem is misalignment: The identity and specifications of the food-contact substance, manufacturing process, intended conditions of use, migration assessment, exposure estimate, and toxicology data do not fully support the same conclusion. Impurities, reaction products, or process changes may also be insufficiently characterized. An effective FCN is not a blanket approval of a finished package; it applies to the identified substance, manufacturer or supplier, and conditions of use. Companies must translate those boundaries into supplier specifications, purchasing controls, and change-notification requirements so the product placed on the market remains compliant and within the authorization.
2. How has the shift toward sustainable and PCR packaging materials impacted regulatory compliance?
Sustainability attributes do not establish food-contact suitability. PCR and other alternative materials can introduce different feedstocks, contaminant profiles, manufacturing processes, and performance characteristics. For recycled plastics, companies may need evidence that the recycling process consistently produces material of suitable purity for the intended food-contact use. Any change in resin, coating, adhesive, recycled-content level, layer structure, or process should trigger an assessment of whether existing authorizations, migration data, and functional testing remain applicable.
Sustainable packaging must satisfy the same safety requirements as conventional packaging.
3. What do non-intentionally added substances (NIAS) mean for testing in practice?
NIAS can include impurities, reaction intermediates, byproducts, and degradation products that were not deliberately added to the finished material. Their evaluation should begin with the formulation, supplier information, and manufacturing process, not with laboratory screening alone. Depending on the potential exposure and hazard, the assessment may include migration modeling, targeted testing, or non-targeted analytical screening. “Non-intentionally added” explains why a substance may be present, but not why that substance is absent, or is safe or not at the resulting exposure.
4. Can you share any real-world challenges of migration testing?
Migration is use-specific, not simply material-specific. Food type, contact time and temperature, package geometry, repeated use, multilayer construction, and barrier performance can all affect the result. That makes it risky to assume that data for a conventional material automatically covers a recycled or redesigned structure. Brands are addressing this by evaluating compliance earlier in material selection, testing representative or appropriately conservative constructions and conditions, and requiring suppliers to disclose those changes that could invalidate the assessment. The strongest programs treat sustainability, food-contact safety, and package performance as parallel design requirements rather than sequential approvals.
With 20 years of dynamic leadership and expertise in regulatory compliance, food safety, and quality systems, Kari Barnes pairs technical precision with a people-first approach as regulatory standards manager at TraceGains. Her background in molecular genetics and food microbiology, backed by a BS in biological sciences, fuels her innovative edge. Driven by a passion for sustainability, environmental protection, and social equity, Kari is dedicated to creating a healthier, more equitable world through smarter global standards.