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:

1. The material composition (what it’s made of)
2. The application (direct contact, indirect contact, type of food)
3. The conditions (temperature, contact duration, type of food)
4. The regulatory framework (FDA, USDA, NSF, 3-A, EU)

A material can be FDA compliant for cold beverages but not for hot fatty foods. Context matters.

FDA Regulations: The Foundation

The FDA regulates food contact materials under 21 CFR (Code of Federal Regulations). Key sections:

21 CFR 177 - Indirect Food Additives: Polymers Lists polymers approved for food contact applications with specific limitations on:

• Types of food (aqueous, acidic, fatty, alcoholic)
• Temperature ranges
• Contact duration
• Maximum extraction limits

21 CFR 178 - Indirect Food Additives: Adjuvants Covers additives and processing aids in food contact materials.

21 CFR 182/184 - Generally Recognized as Safe (GRAS) Materials with long safe-use history.

What FDA compliance means: The material appears on FDA-approved lists for the intended application, and any limitations are respected in use.

What FDA compliance does NOT mean:

• The FDA has tested or certified the specific material
• The material is approved for ALL food applications
• No documentation or verification is required

FDA-Compliant Plastics

The following plastics have FDA-compliant grades available. Note that specific formulations matter—the base polymer may be approved while certain colorants or additives are not.

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: Natural/white/FDA-approved colors only. Random colored materials are typically NOT FDA compliant.

Grade matters: “FDA compliant UHMW” specifically formulated differs from standard UHMW. Always specify FDA grades.

Documentation matters: Suppliers should provide compliance letters confirming the specific material meets FDA requirements.

FDA-Compliant Metals

Metals are generally simpler than plastics for food contact. The primary concerns are:

1. Toxic metals: Lead, cadmium, and other heavy metals must be below limits
2. Corrosion: Material must not corrode into food
3. Surface finish: Must be cleanable, typically Ra 32 µin or better

Commonly Approved Metals

Stainless Steel 304 and 316 stainless are the standard food-grade metals. 316 is preferred where chlorides (salt) are present. Both are approved under FDA regulations and NSF standards.

Aluminum Generally acceptable for food contact when anodized or in non-acidic applications. Raw aluminum can react with acidic foods.

Brass and Bronze Limited approval. Lead-free grades may be acceptable for specific applications. Verify specific alloy compliance.

Avoid:

• Galvanized steel (zinc coating can contaminate acidic foods)
• Leaded brass/bronze
• Uncoated carbon steel (corrosion concerns)
• Cadmium-plated materials

NSF Certification: Beyond FDA

NSF International provides third-party certification that goes beyond FDA compliance. NSF certification means:

• Independent laboratory testing confirms compliance
• Manufacturing processes are audited
• Ongoing surveillance ensures continued compliance
• Products are listed in NSF’s public database

Key NSF Standards

NSF/ANSI 51 - Food Equipment Materials The primary standard for food contact materials and equipment. Covers materials, design, construction, and cleanability.

NSF/ANSI 61 - Drinking Water System Components For materials contacting potable water. Covers extraction testing for contaminants.

NSF/ANSI 14 - Plastics Piping System Components For plastic piping in potable water systems.

When NSF Is Required

• Major food processors often require NSF-listed materials
• Health department inspections may require NSF certification
• Food equipment manufacturers typically specify NSF materials
• Customer specifications increasingly require third-party certification

Key difference: FDA compliance is self-declared; NSF certification is independently verified.

3-A Sanitary Standards

The 3-A Sanitary Standards apply specifically to dairy and food equipment where cleanability is critical. 3-A addresses:

• Material composition
• Surface finish requirements (Ra 32 µin max)
• Design criteria for cleanability
• No crevices, pockets, or dead spots

3-A standards are referenced by USDA for meat and poultry processing equipment.

Application-Based Requirements

Direct vs. Indirect Contact

Direct contact: Material touches food. Must meet FDA requirements for the specific food type and conditions.

Indirect contact: Material is near food but doesn’t touch it (guards, frames, non-contact surfaces). Requirements are less stringent but contamination potential must be considered.

Food Type Categories

FDA classifies foods into categories affecting material requirements:

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

Some materials approved for aqueous foods are NOT approved for fatty foods because fats extract certain compounds more aggressively.

Temperature Considerations

Material approval is temperature-dependent. A plastic approved for room-temperature contact may not be approved for hot-fill applications or cooking temperatures.

Always verify approval at your maximum operating temperature.

Practical Compliance Steps

1. Identify Requirements

• What regulatory framework applies? (FDA, USDA, NSF, customer specs)
• What type of food contact? (direct, indirect, food type)
• What conditions? (temperature, duration, cleaning chemicals)

2. Select Compliant Materials

• Choose materials with established compliance for your application
• Specify FDA-compliant or NSF-listed grades explicitly
• Avoid colored materials unless specifically approved

3. Obtain Documentation

• Request FDA compliance letters from material suppliers
• Obtain Certificates of Compliance for each lot
• Keep NSF listing verification if required
• Maintain documentation for audits

4. Verify Surface Finish

• Specify surface finish on drawings (Ra 32 µin typical)
• Avoid crevices, threads, and features that trap contamination
• Ensure cleanability in design

5. Maintain Traceability

• Document material lot numbers
• Keep supplier certifications on file
• Establish material receiving verification

Common Mistakes

Assuming all plastic is food-safe Standard industrial plastics are not FDA compliant. You must specify FDA grades.

Ignoring the application A material compliant for water may not be compliant for fatty foods or hot applications.

Accepting verbal assurance Always obtain written documentation. “It’s food grade” without paperwork means nothing in an audit.

Overlooking cleaning chemicals Materials must resist not only food but also cleaning and sanitizing chemicals used in operation.

Specifying inappropriate finishes Rough surfaces harbor bacteria. Food contact surfaces require appropriate finishes.

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
• NSF listing verification (where applicable)

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