Sourcing packaging for frozen food means solving two problems at once: the material has to survive sub-zero storage without cracking, fogging, or letting in oxygen, and it has to satisfy two very different regulatory systems if you sell in both the US and the EU. Getting either one wrong is expensive — a brittle tray that splits in the freezer aisle is a recall risk, and a coating that isn’t properly authorized is a compliance risk.
This guide walks through the materials that reliably meet both FDA and EU requirements for frozen food contact, what documentation you should be demanding from suppliers, and the mistakes that trip up buyers most often — including the recent PFAS and bisphenol A (BPA) rule changes that are actively reshaping what’s allowed.
Quick Answer
For frozen food, the materials that consistently clear both FDA and EU review are LDPE film and bags, impact-modified or copolymer polypropylene (PP) trays and tubs, crystallized PET (CPET) for dual-ovenable trays, EVOH as a barrier layer in multilayer laminates, and aluminum foil or foil trays. Paperboard cartons work too, but only with a PFAS-free, properly authorized moisture/grease barrier coating. In every case, compliance is not just about the base resin — it’s about the coatings, inks, and adhesives layered onto it, and about getting the right supplier documentation before you commit to a run.
Materials That Meet FDA and EU Standards for Frozen Food
LDPE (low-density polyethylene) is the workhorse for frozen food bags and overwrap film — it stays flexible at freezer temperatures, resists moisture, and is listed as an authorized food-contact polymer under both US and EU frameworks. Standard homopolymer polypropylene, by contrast, can go brittle and crack in a freezer; for rigid trays and tubs, specify an impact-modified or copolymer PP grade rated for frozen or freeze-thaw use rather than a generic ‘food grade’ PP.
Crystallized PET (CPET) is the standard choice for ready-meal trays that need to go straight from freezer to oven or microwave, since it holds up at both temperature extremes. Where oxygen ingress is the risk — frozen seafood, meat, or produce prone to freezer burn — manufacturers use EVOH (ethylene vinyl alcohol) as a thin barrier layer sandwiched inside a multilayer PE or PET laminate; EVOH alone is moisture-sensitive, so it’s never used as the outer layer. Aluminum foil and foil trays offer the strongest total barrier to oxygen, light, and moisture and fall under the ‘metals and alloys’ category of food contact materials, but cost more and aren’t microwave-compatible. Paperboard cartons remain common as secondary or outer packaging, but any coating that provides grease or moisture resistance needs its own authorization — this is exactly the layer that got upended by the PFAS phase-out described below.
FDA vs. EU: What Compliance Actually Requires
In the US, the FDA regulates packaging materials as ‘food contact substances’ under Title 21 of the Code of Federal Regulations, with different parts covering different material types: Part 174 sets general provisions, Part 175 covers adhesives and coatings, Part 176 covers paper and paperboard, and Part 177 covers polymers like PE, PP, and PET. New or modified substances typically clear the market through a Food Contact Notification (FCN) reviewed by the FDA, and that authorization is tied to specific conditions of use — including temperature — so a substance cleared for dry food storage isn’t automatically cleared for frozen use.
The EU works differently. Regulation (EC) 1935/2004 is the framework law requiring that any material intended for food contact not transfer substances into food at unsafe levels. Article 16 adds a written Declaration of Compliance (DoC) requirement, but only for material categories that have their own EU-level ‘specific measure’ — currently plastics, ceramics, regenerated cellulose film, and materials containing BADGE-type substances. Plastics are the category most relevant to frozen food packaging, and they carry an additional layer of rules under Regulation (EU) 10/2011, which sets an overall migration limit of 10 mg per dm² of contact surface (or 60 mg/kg of food) plus substance-specific migration limits, tested under time/temperature conditions matched to how the packaging is actually used — frozen storage, plus any reheating step. Materials without a dedicated EU measure, such as most paperboard and aluminum foil, still fall under the general Article 3 safety obligation, but aren’t legally required to carry a formal DoC — even so, reputable suppliers of any material will typically provide supporting compliance documentation on request.
Two rule changes are actively reshaping sourcing right now. On the US side, the FDA revoked authorization for 35 food contact notifications tied to PFAS-based grease-proofing agents in paper and paperboard packaging, with a compliance date of June 30, 2025 for existing inventory — and a growing list of states independently restrict PFAS in fiber-based food packaging. On the EU side, Commission Regulation (EU) 2024/3190 banned BPA and several related bisphenols from plastics, coatings, inks, and adhesives used in food contact materials, effective January 20, 2025, with phased compliance deadlines running from mid-2026 through 2029 depending on the article type.
Tips and Common Mistakes
Don’t accept a generic ‘food grade’ claim as proof of frozen-food compliance — ask the supplier to confirm the material’s authorization covers your specific temperature range and reheating conditions, not just room-temperature food contact. Push past the base resin, too: compliance failures usually hide in the coating, ink, or adhesive layer rather than the plastic or paperboard itself, so request supporting documentation that explicitly names every layer of the structure — a formal DoC for plastics and other regulated categories, and a letter of guarantee or migration data for materials like paperboard that don’t have a mandatory DoC requirement.
Given the pace of change on PFAS and BPA, get written, dated confirmation that a material is PFAS-free and bisphenol-free rather than relying on older certificates — documentation issued before 2025 may no longer reflect current status. Finally, if you’re qualifying dual-ovenable trays, test for both freezer brittleness and oven heat resistance; a tray that passes one test can still fail the other.
Explore more: more packaging compliance guides.
Frozen food packaging compliance FAQs
What’s the difference between FDA and EU compliance for frozen food packaging?
The FDA authorizes specific substances for specific conditions of use under 21 CFR Parts 174-178, typically via a Food Contact Notification. The EU uses the Regulation 1935/2004 framework, plus material-specific rules like Regulation 10/2011 for plastics. A formal Declaration of Compliance is legally mandatory only for material categories with their own EU measure — mainly plastics, ceramics, and regenerated cellulose film — though buyers should still request supporting documentation for other materials.
Is polypropylene safe for frozen food packaging?
Yes, PP is authorized for food contact under both FDA and EU rules, but standard homopolymer PP can crack or go brittle at freezer temperatures. For frozen applications, specify an impact-modified or copolymer PP grade rated for low-temperature or freeze-thaw use.
Do frozen food packaging suppliers need to provide PFAS-free certification?
It’s increasingly expected. The FDA revoked authorization for PFAS-based grease-proofing agents in paper packaging, with a June 30, 2025 compliance date, and multiple US states restrict PFAS in fiber-based food packaging independently. Buyers should request written, current PFAS-free confirmation, especially for paperboard and molded-fiber components.
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Photo: Government of the Russian Federation / CC BY 4.0, via Wikimedia Commons.