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Can Substances Cleared in Section 175.300 Be Cross-Referenced into Other Regulations?

December 18, 2014
Question 

I understand that substances permitted for use in coatings, according to 21 C.F.R. Part 175.300, are also permitted to be used in adhesives (175.105) because there is the additional requirement of a functional barrier. Are the substances listed in 175.300 also permitted to be used in other food-contact materials (i.e., polyurethane resins 177.1680)?

Answer 

The answer to your question depends on the end use. While Title 21 of the Code of Federal Regulations (C.F.R.), Part 175.300 is commonly referred to as the "can coatings" regulation, it does permit coatings to be used on "any suitable substrate," provided the product of interest is limited to repeat-use. Single service applications, however, are restricted under Section 175.300 to metal substrates. For example, if the end use of the polyurethane resin is a coating for a repeat-use or metal food-contact item, then the clearance in Part 175.300 would apply provided the coating is of suitable purity for the intended use.

Section 175.300 also permits the use in coatings of substances that are generally recognized as safe (GRAS), prior sanctioned, or the subject of another food additive regulation, provided that the substance, when used in coating applications, complies with the specifications and limitations listed in the cross-referenced regulation. For more information, see the PackagingLaw.com article, What's Under the Coat of Section 175.300?