Gluing in Food and Primary Packaging: What Certificates of Conformity Should Be Requested?
For food packaging gluing, the Technical Data Sheet (TDS) alone is not proof of suitability for food contact. In order for an adhesive to be considered food safety approved, a comprehensive 'Declaration of Compliance - DoC' must be obtained from its manufacturer. This declaration must reference EU (EC) No 1935/2004 and Good Manufacturing Practice (EC) No 2023/2006 or US FDA 21 CFR 175.105 (indirect food contact); Direct contact (primary) and secondary packaging layers should be clearly separated and mineral oil hydrocarbon migration limits such as MOSH/MOAH should be documented.
The performance of the adhesive used in the food and beverage industry when closing cardboard boxes, biscuit packages, tea bags, frozen food parcels or beverage trays cannot be measured by mechanical adhesion alone. Migration of chemical vapors or harmful components into the foodstuff inside the packaging may threaten the health of the consumer and expose producers to serious legal sanctions and product recall crises.
The most common misconception in the industry is to assume that the adhesive's Technical Data Sheet (TDS) writing "suitable for packaging" provides legal food contact approval. As Koçak Endüstri, we offer legally documented supply assurance with Jowat packaging glues and food sectoral solutions in accordance with official regulations for food and primary packaging manufacturers.
Legal regulations and regulatory framework in food packaging
Food contact materials (FCM) are subject to very strict legal regulations globally:
- European Union (EU) Framework: In accordance with Framework Regulation (EC) No 1935/2004 , materials cannot transfer components into food in amounts that would endanger human health or spoil the composition, taste and odor of the food under normal use conditions. In addition, must be produced in accordance with (EC) No 2023/2006 Good Manufacturing Practice (GMP) .
- US FDA Regulations: FDA 21 CFR 175.105 (Adhesives) defines a positive list of raw materials for which adhesives can be safely used as indirect additives in food contact materials.
- Turkish Food Codex: Analysis reports and declarations of packaging glues imported and produced in accordance with the Regulation on Substances and Materials in Contact with Food must be complete.
Why TDS is not enough? Declaration of Conformity (DoC) obligation
TDS only describes the physical parameters of the product such as viscosity, open time and melting point; does not provide a legal guarantee. The only official document accepted in food packaging inspections is the Declaration of Compliance (DoC) document, which is signed/sealed by the manufacturer. This document should clearly state which food types the adhesive can be used with (dry, fatty, aqueous, acidic), in what temperature range and behind which barrier layers.
Primary packaging and secondary packaging gluing separation
| Direct food contact approval; Zero harmful substance passage is mandatory. | |||
| Packaging with Functional Barrier | Outer cardboard box of the biscuit in an aluminum or polyethylene bag | Plastic/metalized foil barrier available | Indirect food contact (FDA 175.105); low volatile organic compound (VOC). | Standard case closing hotmelt; Odor-free, clean-melting formula. |
Chemical migration risk: Odor, taste and MOSH/MOAH limits
The most critical technical risk in food packaging is the evaporation of mineral oil hydrocarbons (MOSH - Saturated, MOAH - Aromatic) and leakage into the food. Glues containing low-quality recycled raw materials or uncontrolled resins can cause off-flavors in fatty foods such as baked goods and chocolate. For this reason, high purity synthetic polyolefin (PO) and high purity EVA hotmelts are preferred in modern food lines.
5-item document checklist that the buyer will request from the supplier
- Manufacturer's Declaration of Conformity (DoC): Current document with reference to EU 1935/2004 and FDA 175.105, with product code indicated.
- Global Migration Test Report: Test results made with food simulants (water, 3% acetic acid, 10% ethanol, olive oil) by accredited laboratories.
- Heavy Metal and Phthalate Declaration: RoHS, REACH and lead/cadmium/phthalate-free analysis commitment.
- MOSH / MOAH Levels of Analysis: Mineral oil risk assessment, especially for bakery and dry food cans.
- Odor Evaluation Report (Robinson Test / DIN 10955): Sensory confirmation that the glue does not transmit foreign odors and tastes to the food during storage.
Jowat industrial packaging solutions for food lines
Jowat packaging adhesives series that we offer as Koçak Endüstri; It consists of formulations that do not contain odor and color, have high thermal stability, do not cause carbonization in the nozzles and are fully compatible with international food safety certificates. Our low temperature cool melt options for your folding box gluing and box closing lines maximize food packaging safety while saving energy.
Stock and technical consultancy
You can contact our Koçak Endüstri technical team to supply DoC certified adhesives that are fully compliant with inspections in your food production lines and to evaluate your current packaging structure in terms of migration.
Gluing in Food and Primary Packaging: What Certificates of Conformity Should Be Requested? hakkında merak edilenler
Is TDS certificate sufficient for food packaging glue?
No. TDS indicates physical specifications only. For legal inspections, a Declaration of Compliance (DoC) signed by the manufacturer and migration tests are required.
What does FDA 175.105 certification mean?
It is the standard established by the US Food and Drug Administration (FDA) that certifies that the adhesive does not come into direct contact with food and can be used safely in indirect contact behind a functional barrier.
Does the MOSH/MOAH risk transfer from glue to food?
In glues containing low-quality petrochemical resins, mineral oil hydrocarbons can evaporate and pass into food; Therefore, high purity synthetic PO or special EVA should be chosen for food packaging.
Can any hotmelt be used in primary packaging?
No. Only special certified food glues can be used on primary layers with direct food contact; Standard packaging glues can only be used in secondary packaging.
Technical resources and verification
The content has been prepared in Turkish with the technical experience of Koçak Endüstri, based on the following manufacturer resources.
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