
Legal requirements for food packaging
Food packaging regulations are vital for protecting consumers’ health, which is why numerous stringent laws and legislation exist for this purpose.
Primary food packaging, in addition to maintaining product freshness, should also prevent harmful substances from entering the food. It can also provide essential information, such as nutritional details, use-by dates and allergen warnings. Food businesses must adhere to applicable regulations to avoid legal penalties, maintain their production licenses, and preserve consumer trust.
GWP Group does not provide primary packaging for food (i.e. that which is in direct contact with food, unless the food is intended to be washed or peeled before consumption). However, we can assist your business with general transit packaging, temperature-controlled options, and even point-of-sale displays for retail environments.

Table of contents
The following regulations apply to food packaging in the UK. Please note that this list is not exhaustive and is subject to change as regulations are updated, introduced, or replaced. Not all rules apply to all forms of food packaging.
- The Packaging (Essential Requirements) Regulations 2015
- Extended Producer Responsibility (EPR)
- Regulation (EC) No 852/2004 Food Hygiene
- The Waste (England and Wales) Regulations 2011
- DS EN ISO 14021 Environmental Labels and Declarations
- International Plant Protection Convention (IPPC) – ISPM 15
- IATA (Dangerous Goods Rules)
- The Food Contact Materials and Articles (England) Regulations
- Regulation (EC) No 1935/2004 Food Contact Materials
- Regulation (EC) No 2023/2006 Goods Manufacturing Practice (GMP)
- The Food Information Regulations 2014 (FIR)
- Food Safety Act 1990
- UK Food Hygiene Regulations (EC) No 852/2004
- EU Regulation (EU) No 10/2011 Plastic Food Contact Materials
- FDA 21 CFR Parts 170-199 US Food Contact Substances
- Codex Alimentarius – General Principles of Food Hygiene (CAC/RCP 1-1969)
- BRCGS Packaging Materials Standard (Issue 6)
- ISO 22000 Food Safety Management Systems (FSSC)
- EN 15593 Hygiene Management in Packaging Manufacturing
The Packaging (Essential Requirements) Regulations 2015
The UK law that applies to all packaging, including food packaging, and states that:
- Packaging must be minimised, recyclable, and free from heavy metals.
- Encourages eco-friendly design principles in all packaging.
- Applies to both retail and transit packaging.
GWP Group statement
Our design approach at GWP ais to always minimise material use and aid recyclability for end users. We place significant emphasis on eco-friendly design, as evidenced by our Starpack Awards (including the Green Star award in 2018). This is in addition to a wide range of sustainability initiatives throughout our business.
We do not use any heavy metals or other dangerous chemicals/materials in the packaging we manufacture.
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Extended Producer Responsibility (EPR)
In 2023, the Extended Producer Responsibility (EPR) legislation was introduced, which states that producers must report and pay for packaging waste based on the type and volume they use.
For example, electronics exporters must track material use, recyclability, and labelling (e.g., “widely recycled” icons). This legislation applies to products and shipping packaging.
GWP Group statement
GWP Group can help our customers comply with their legal responsibilities under EPR through supplying detailed product and usage statistics. Please note we are not able to submit EPR figures/returns directly for our customers, and this remains their responsibility. GWP can, on request, print any applicable logos or legal information on our customers packaging, providing this information is supplied to us in print ready arwork files prior to manufacture. GWP cannot take responsibility for the omission of or inclusion of incorrect information on our customers packaging.
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Regulation (EC) No 852/2004 Food Hygiene (Retained in UK law)
This standard applies if transit packaging is used in a food-handling area and states that shipping materials (e.g., reusable crates) must be clean, intact, and non-contaminating.
GWP Group statement
GWP Group can supply reusable crates that can meet Regulation (EC) No 852/2004 Food Hygiene. Correx is a particular good option for this. However, due to the reusable nature of such packaging, it is the customer/end users responsibility to ensure that any crates etc. remain clean and in sufficiently good condition.
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The Waste (England and Wales) Regulations 2011
This standard governs the handling, transport, and disposal of transit packaging waste and states that exporters must manage packaging waste and reuse systems, especially for returnable transit packaging (RPT).
GWP Group statement
The disposal of packaging is the responsibility of our customers, and not GWP. However, we can assist through providing packaging that is safe to handle, easy to recycle, and minimises material use.
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DS EN ISO 14021 - Environmental Labels and Declarations
A voluntary standard, but often applied to transit packaging with claims like “recyclable”, “biodegradable”, or “compostable”. It ensures honest, evidence-based environmental claims on shipping cartons, outer labels, etc.
GWP Group statement
GWP Group typically prints any packaging we manufacture with artwork/information supplied by our customers. It is our customers responsibility to ensure that such information is accurate and complete. GWP can advise on suitable information and/or symbols to include (e.g. incorporating FSC logos).
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International Plant Protection Convention (IPPC) - ISPM 15
The global standard for wood packaging (pallets, crates, dunnage) states:
- Exported wooden packaging must be heat-treated or fumigated and stamped with the IPPC mark.
- Prevents the spread of pests across borders.
- Mandatory for many export destinations, including the EU, US, China, Australia.
GWP Group statement
All timber that GWP Group uses in the packaging/products we manufacture complies with ISPM 15 requirements. This includes relevant markings (i.e. ISPM 15 stamp).
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IATA (Dangerous Goods Rules)
This standard only applies if the food shipment contains dry ice, alcohol, or other hazardous items. The transit packaging must comply with dangerous goods packaging standards, if applicable.
GWP Group statement
Please see separate section regarding dangerous goods packaging.
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The Food Contact Materials and Articles (England) Regulations 2012
This regulation implements retained EU rules on materials intended to come into contact with food, and states that:
- Food packaging is to be kept safe (no harmful migration into food).
- Manufacturers must hold Declarations of Compliance (DoCs) for certain materials.
- This applies to plastic, paper, glass, adhesives, coatings, etc.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
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Regulation (EC) No 1935/2004 Food Contact Materials (Retained UK Version)
This is the core food safety regulation retained within UK law. It states that:
- Materials used must not endanger health, change food composition, or affect taste or smell.
- Labelling and traceability is required on all food-contact packaging.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
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Regulation (EC) No 2023/2006 Goods Manufacturing Practice (GMP)
This standard sets hygiene and quality standards for food-contact packaging production. It applies to packaging suppliers and converters and states that good packaging must be manufactured under controlled and documented processes.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
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The Food Information Regulations 2014 (FIR)
These regulations govern what information must appear on food labels.
It states that labels on food packaging must include:
- Ingredients
- Allergens
- Net quantity
- Durability rate
- Business name/address
- Country of origin (if applicable)
Labelling must be legible, accurate, and in English.
GWP Group statement
The responsibility for accurate and suitable information, printed or otherwise added to packaging we supply, is the responsibility of our customers. GWP Group will add information based on artwork supplied by customers for their specific packaging lines, and cannot be held responsible for the accuracy or suitability of this.
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Food Safety Act 1990
This is the core food safety law that covers packaging design, labelling, and contamination risks. It states that packaging must not render food injurious, misleading, or falsely labelled.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
The responsibility for accurate and suitable information, printed or otherwise added to packaging we supply, is the responsibility of our customers. GWP Group will add information based on artwork supplied by customers for their specific packaging lines, and cannot be held responsible for the accuracy or suitability of this.
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UK Food Hygiene Regulations (EC) No 852/2004
These regulations lay down the hygiene rules for food businesses, and states that:
- Packaging must protect food from contamination.
- Hygienic storage and use of packaging is required within food facilities.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
The storage of packaging within premises producing or handling food products is the responsibility of the business carrying out such activities.
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EU Regulation (EU) No 10/2011 Plastic Food Contact Materials
The EU-specific regulations on plastic materials that are used in food packaging. This regulation is relevant for UK exporters selling to the EU or Northern Ireland and requires migration testing and a positive list of authorised substances.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
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FDA 21 CFR Parts 170-199 US Food Contact Substances
This is the US regulation of packaging materials for food. It states that food packaging must be:
- GRAS (Generally Recognised as Safe).
- Covered by an FCN (Food Contact Notification).
- Compositional and safety tested (required for export to the US).
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
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Codex Alimentarius - General Principles of Food Hygiene (CAC/RCP 1-1969)
The global food hygiene guidance that influences national food safety systems in developing and export-focused countries states that packaging must prevent contamination during handling and distribution.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
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BRCGS Packaging Materials Standard (Issue 6)
The UK-origin global certification for food packaging suppliers that covers hygiene, GMP, traceability, and material safety. It is often required by retailers and manufacturers globally.
GWP Group statement
GWP Group does not manufacture or supply any packaging intended for direct contact with food products.
Our parent company, Macfarlane Group, holds BRCGS certification for several sites across its’ UK operations.
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ISO 22000 Food Safety Management Systems (FSSC)
The Food Safety Management System (FSMS) based on Hazard Analysis and Critical Control Point (HACCP) principles, that:
- Ensures food packaging operations are part of a controlled food safety environment.
- Helps to mitigate packaging contamination risks.
GWP Group statement
Adherence to ISO 22000 Food Safety Management Systems (FSSC) is the reponsibility of the business carrying out such activities. GWP Group can work alongside customers where there is overlap between these operations and the secondary (i.e. non food contact) packaging they use.
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EN 15593 Hygiene Management in Packaging Manufacturing
The European hygiene standard for packaging production that helps ensure clean, safe, and contaminant-free packaging is accepted in many EU and UK supply chains.
GWP Group statement
GWP Group is not currently able to supply packaging that complies with EN 15593 Hygiene Management in Packaging Manufacturing.
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Disclaimer
The information provided on this page is intended as a guide only. GWP can accept no responsibility or liability for loss, damage or any other consequence of reliance on this information, howsoever caused. As all applications and scenarios vary, it is your responsibility or the responsibility of your business to ensure that any products or items you manufacture and/or distribute comply the regulations applicable to your specific circumstances. If in any doubt, please check with the appropriate regulatory body.