Food Packaging for Export: Compliance Requirements by Destination Country

India's food exports crossed USD 50 billion in the 2023-24 fiscal year, and food packaging is an integral part of every exported consignment. But the packaging requirements for food exports are not the same as domestic requirements. Each destination country has its own food contact material regulations, labelling laws, language requirements, and import procedures. Packaging that is perfectly compliant for the Indian domestic market may be rejected at the port of a destination country if it does not meet their specific standards.

This guide provides a country-by-country overview of food packaging requirements for the most important export destinations from India, along with the Indian-side export procedures and documentation.

Indian-Side Export Requirements

APEDA Registration

The Agricultural and Processed Food Products Export Development Authority (APEDA), established under the APEDA Act, 1985, is the nodal agency for food exports from India. Exporters of scheduled food products must register with APEDA (Registration-cum-Membership Certificate, or RCMC). APEDA registration is a prerequisite for obtaining APEDA subsidies and participating in APEDA-facilitated export promotions.

FSSAI Export Licence

Under the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011, any food business operator exporting food products requires a Central FSSAI licence. The licence application must specify the categories of food being exported. The FSSAI export licence is separate from and additional to the state FSSAI licence that the same business may hold for domestic operations.

Export Inspection Council (EIC)

The Export Inspection Council of India, under the Ministry of Commerce, operates export inspection schemes for certain food products. Products covered under compulsory pre-shipment inspection must be inspected and certified by the Export Inspection Agency (EIA) before export. The inspection covers both the food product and its packaging.

Destination Country Requirements

European Union

The EU has the most comprehensive food contact material regulations in the world. The governing framework includes:

• Regulation (EC) 1935/2004: The framework regulation for all food contact materials. Establishes the principle that food contact materials must not transfer their constituents to food in quantities that could endanger health, cause unacceptable changes in composition, or deteriorate sensory properties.
• Regulation (EU) 10/2011: The specific regulation for plastic food contact materials. Lists all authorised substances (positive list), sets specific migration limits for each substance, and prescribes overall migration limits and testing methods. India's IS 9845 is substantially aligned with this regulation.
• Regulation (EC) 2023/2006: Good Manufacturing Practice (GMP) for food contact materials. Requires manufacturers to operate a quality management system that ensures food contact materials consistently meet applicable requirements.

For Indian exporters, the key requirement is a Declaration of Compliance (DoC) -- a written declaration by the packaging manufacturer or supplier stating that the material complies with EU food contact regulations. This DoC must be available to the food manufacturer, the importer, and the enforcement authorities throughout the supply chain.

EU Requirement	Indian Equivalent	Gap / Action Needed
Overall migration: 10 mg/dm2	IS 9845: 10 mg/dm2 (60 mg/kg)	Aligned; no gap
Positive list of authorised substances	No comprehensive positive list in India	Verify all additives against EU Annex I of Regulation 10/2011
Declaration of Compliance (DoC)	No formal DoC requirement in India	Must prepare DoC specifically for EU exports
Traceability (one step back, one step forward)	Limited traceability requirements	Implement batch traceability system

United States (FDA)

The US Food and Drug Administration regulates food contact materials under the Federal Food, Drug, and Cosmetic Act (FD&C Act), Section 409. The regulatory approach differs from both India and the EU:

• Food Contact Notification (FCN): New food contact substances must be notified to the FDA through the FCN process before they can be marketed. The FDA maintains a database of authorised food contact substances.
• 21 CFR Parts 170-199: The Code of Federal Regulations specifies requirements for food additives, including substances used in food packaging. Part 177 covers indirect food additives (polymers), Part 175 covers adhesives and coatings, and Part 176 covers paper and paperboard.
• FDA Prior Notice: All food shipments (and their packaging) entering the US must have prior notice filed with the FDA through the Prior Notice System.

For Indian exporters, the FDA does not require a pre-market approval for packaging in most cases if the materials used are listed in the applicable CFR parts. However, the exporter or their US importer must be able to demonstrate compliance on request. Migration testing should be conducted using FDA-prescribed methods (which differ slightly from IS 9845) and FDA food simulants.

Gulf Cooperation Council (GCC) Countries

Saudi Arabia, UAE, Kuwait, Qatar, Bahrain, and Oman follow the GSO (Gulf Standardization Organization) standards for food contact materials. Key requirements include GSO 839 for overall migration limits (aligned with Codex Alimentarius), specific requirements for printing inks on food packaging (GSO 2231), Halal certification requirements for packaging materials, Arabic language labelling (mandatory), and SASO (Saudi Standards Authority) or ESMA (Emirates Authority for Standardization) conformity assessment for certain products.

India is the largest food exporter to the GCC region. Packaging compliance, particularly Arabic labelling and Halal certification, is the most common reason for consignment rejections.

ASEAN Countries

ASEAN member states (Indonesia, Malaysia, Thailand, Vietnam, Philippines, Singapore, and others) are harmonising food contact regulations under the ASEAN Food Safety Regulatory Framework. Key requirements include BPOM (Indonesia) food contact material registration, JAKIM Halal certification for Malaysia, Thai FDA notification for food contact materials, and Singapore Food Agency (SFA) compliance requirements.

For Malaysian exports specifically, Halal certification of packaging is a significant requirement due to JAKIM's comprehensive Halal standards that cover the entire supply chain.

Labelling Requirements for Export Packaging

Labelling is the most frequent compliance failure point for Indian food exporters. Each destination country has specific labelling requirements:

Market	Language	Key Label Requirements
EU	Official language of the destination member state	Nutrition declaration per Regulation 1169/2011; allergen emphasis; origin marking; best before / use by
USA	English	Nutrition Facts panel (FDA format); allergen declaration (Big 9); country of origin; net weight in US units
GCC	Arabic (mandatory) + English	Production and expiry dates in Gregorian; Halal statement; importer details
Japan	Japanese	Nutrition label per MHLW format; allergen declaration (28 items); additive listing
Australia / NZ	English	Nutrition Information Panel (NIP); country of origin per Australian Consumer Law; allergens

Export Documentation Checklist

• Valid Central FSSAI licence with export scope
• APEDA Registration-cum-Membership Certificate (RCMC) for scheduled products
• Importer Exporter Code (IEC) from DGFT
• Commercial invoice, packing list, and shipping bill
• Certificate of Origin (preferential or non-preferential as applicable)
• Phytosanitary Certificate from Plant Quarantine Authority (for plant-based food products)
• Health Certificate from EIC or FSSAI (as required by the destination country)
• Migration test report compliant with the destination country's standards (EU Regulation 10/2011, FDA 21 CFR, etc.)
• Declaration of Compliance (DoC) for food contact materials (EU requirement)
• Halal certificate from a certification body recognised by the destination country (for GCC/ASEAN exports)
• Organic certification documents (if exporting organic food products)
• Label artwork approved for the destination country's requirements
• Insurance certificate covering the export consignment

Common Export Rejection Reasons Related to Packaging

• Incorrect labelling language: English-only labels sent to GCC markets without Arabic translation
• Migration test reports in wrong format: IS 9845 report submitted for EU market instead of EU 10/2011 compliant report
• Missing Halal certificate: Consignment to Malaysia or Saudi Arabia without Halal certification
• Allergen declaration format: Indian allergen list submitted instead of the destination country's specified allergen list
• Net weight in wrong units: Metric-only declaration for US market (requires US customary units)
• Missing country of origin: "Made in India" statement absent or not prominent enough

Each rejection costs the exporter not just the value of the consignment but also re-export or destruction costs, reputation damage with the importer, and potential future scrutiny from the destination country's authorities.

Success Marketing works with food exporters across India, providing food-grade packaging with the compliance documentation needed for both domestic and export requirements. Our experience since 1991 means we understand what different markets demand.