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What are requirements for testing and analyzing tea bag filter paper as a food-contact material?

July 25, 2008
Question 

We are a tea bag packaging company and buy tea bag filter paper for packing tea bags. What are requirements for testing and analysizing filter paper as food contact materials?

Answer 

Paper used to make tea bags is regulated under Title 21 Code of Federal Regulations (CFR) Section 176.170, which is the provision of FDA's food additive requirements that addresses "Components of paper and paperboard in contact with aqueous and fatty foods." Under this regulation, paper used in contact with food must be manufactured with substances listed in Section 176.170 (and used such that any limitations in the regulation with regard to those substances are met) and meet the extractive specifications identified in Section 176.170(c). The method for conducting the extractive end-test is set out in the regulation.

In addition, as with any food packaging material, paper and paperboard intended to contact food must comply with FDA's good manufacturing practices (GMP) regulation, 21 CFR Section 174.5 ("General provisions applicable to indirect food additives"). Section 174.5 is FDA's implementation of Section 402(a) of the Federal Food, Drug, and Cosmetic Act (the General Safety Clause). Specifically, Section 174.5(a)(2) requires that food-contact materials be of a "purity suitable for [their] intended use."