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Please Explain FDA Coatings Regulations

July 16, 2007
Question 

If a food contact article which substrate material is FULLY covered by color coating (paint). (1) Is this coating regarded as "polymeric coating" under FDA 175.300? (2)Then, should the substrate material also comply with corresponding requirement (e.g., if the substrate is PP, then, should it comply the requirement of 177.1520?)?

Answer 

The U.S. Code of Federal Regulations (21CFR) Part 175.300 clears coatings for metal substrates and for any suitable substrate that is intended for repeated-use applications. Assuming the coating complies with the compositional and extractive requirements of 175.300, than it can be used in the manor you described. Keep in mind, the colorant used in the coating must also comply with the regulation. As for your second question, the substrate must also comply with an appropriate regulation or be the subject of an applicable exemption in order to be used in a food contact application.