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What Are the Requirements for Label Adhesives Used on Exterior of Container?

October 18, 2011
Question 

I own a vodka brand and am currently looking for a new adhesive to keep our labels in place. The label is on the outside of the bottle. It never comes into contact with the vodka. Would the glue need to be FDA approved?

Answer 

The adhesive would not necessarily need to be cleared by the U.S. Food and Drug Administration (FDA) if it is separated from the vodka by a functional barrier. While Title 21 of the U.S. Code of Federal Regulations (C.F.R.) section 175.105 (aka the adhesive regulation) includes a list of substances cleared by FDA for use in adhesive formulations intended for the packaging, transporting, or holding of food, the regulation also states that manufacturers of finished food packaging must ensure that adhesives are either separated from food by a functional barrier, or meet certain requirements. In addition, the Federal Food, Drug, and Cosmetic Act defines a "food additive" as a substance that is reasonably expected to become a component of food under the intended conditions of use. Consequently, in many cases, adhesive formulations contain substances that are not explicitly listed in Section 175.105 but may still be used as intended, provided that the way in which they are used in the finished food packaging ensures that the adhesive is separated from food by a functional barrier or otherwise used in a way that prevents their migration to food. For more information, see the PackagingLaw.com articles, The Regulation of Packaging by the Alcohol and Tobacco Tax and Trade Bureau: An Added Level of Complexity and FDA Regulation of Adhesives in Food Packaging.