BRC, FDA or EU? Match Food Certification to Your Market

Food-contact packaging compliance differs by destination market, and matching the right documentation to your buyer’s actual requirement matters more than a single generic “food safe” claim. BRC (now BRCGS) is a packaging safety certification widely required across UK and EU retail supply chains. FDA governs US food-contact material requirements. EU 1935/2004 and EU 10/2011 form the EU’s own direct regulatory framework. They serve similar purposes but answer to different authorities, and documentation for one rarely satisfies another.

Certification and Regulation Comparison

Scheme	Region	What it covers	Who typically requires it
BRC / BRCGS	UK, widely adopted across EU	Packaging site food safety management systems	UK/EU retailers across their supply chains
FDA	United States	Food-contact material safety requirements	US buyers and importers
EU 1935/2004	European Union	Framework regulation — traceability, conformity declaration	Direct EU market sale
EU 10/2011	European Union	Specific migration limits for plastic food-contact materials	Direct EU market sale, plastics specifically

BRC (BRCGS): A Retail Supply Chain Requirement

BRC, now formally BRCGS (Brand Reputation through Compliance Global Standards), is a certification scheme covering a packaging manufacturer’s food safety management systems — process controls, hygiene, traceability — rather than certifying an individual product. It’s most relevant when your buyer is a UK or EU retailer that requires BRCGS certification across their entire supply chain as a condition of doing business, regardless of whether the packaging itself ever directly touches food (an FIBC liner does, the outer bag typically doesn’t). If your buyer hasn’t specifically asked for BRCGS, it may not be the relevant certification for your situation.

FDA: The US Market Requirement

FDA sets requirements for food-contact material safety in the US market, covered in more detail in our food grade bulk bags guide — the short version is that the FDA doesn’t certify packaging products directly but sets material and process requirements that a liner and production method need to meet, documented through compliance statements rather than a single certificate. This is the relevant standard for US-bound shipments specifically, not a universal requirement for every market.

EU 1935/2004 and EU 10/2011: The EU’s Own Framework

EU Regulation 1935/2004 is the framework regulation governing materials intended to come into contact with food across the EU, requiring traceability through the supply chain and a declaration of conformity confirming the material won’t transfer harmful substances into food beyond safe limits. EU 10/2011 adds specific migration limit rules for plastic food-contact materials — directly relevant to a PE liner’s compliance for EU-bound shipments. These are EU regulations, not certifications in the same sense as BRCGS — compliance is demonstrated through documentation and testing against specific migration limits, not a single certificate.

Why These Aren’t Interchangeable

Each of these addresses food safety and packaging compliance, but through different mechanisms and for different markets — BRCGS certifies a manufacturing site’s management systems, FDA sets US material requirements, and EU regulations set direct legal requirements for the EU market with their own testing and documentation standards. A supplier holding one doesn’t automatically hold or qualify for the others, and a buyer in one market generally won’t accept documentation designed for a different market’s specific framework as a substitute.

What to Ask Your Supplier For, By Market

If you’re selling into the UK or EU retail channel, ask specifically whether the manufacturing site holds current BRCGS certification. If you’re selling into the US, ask for documentation showing the liner material and production process meet FDA-relevant requirements. If you’re importing directly into the EU as the responsible party, ask for a declaration of conformity under EU 1935/2004 and migration test data under EU 10/2011 for the specific liner material used. Don’t accept a general “food safe” claim as a substitute for the specific documentation your actual market requires.

We work directly with partner factories in Shandong; ask us which specific certifications and regulatory documentation a given factory can support for your target market rather than assuming broad food safety credentials cover every requirement automatically.

Common Mistakes When Navigating Multiple Standards

• Assuming FDA compliance satisfies EU or BRCGS requirements. Each framework has its own scope and documentation — meeting one doesn’t automatically satisfy another.
• Treating BRCGS as a product certification rather than a site certification. It certifies the manufacturing site’s management systems, not a specific bag’s individual compliance.
• Not asking your buyer which specific standard they need. Guessing wastes time and can mean sourcing the wrong documentation entirely for your actual market.
• Assuming a supplier’s general “food grade” marketing claim covers a specific regulatory requirement. Push for the specific certification or regulation number relevant to your market.
• Overlooking that EU migration limits are material-specific. A liner material tested and compliant under EU 10/2011 for one formulation doesn’t automatically extend to a different liner material or thickness.

Multiple Markets Mean Multiple Documentation Sets

If you’re selling into more than one market — say, both US and EU customers — you likely need separate documentation for each, since FDA compliance and EU 1935/2004/10/2011 compliance are assessed independently even when the underlying liner material might reasonably meet both. Don’t assume one document set covers multiple markets; confirm what’s actually needed for each destination separately, and budget the time to gather multiple compliance packages if your customer base spans regions.

Decision Checklist

1. What market is your buyer in — UK/EU retail, US, or direct EU import? This determines which specific standard actually applies.
2. Has your buyer specified which certification or regulation they require? Ask directly rather than guessing.
3. Are you confirming site-level certification (BRCGS) versus material-level compliance (FDA, EU regulations)? These are different types of documentation addressing different questions.
4. Does your liner material have migration test data if you’re EU-bound? EU 10/2011 compliance depends on the specific material tested, not a general claim.
5. Have you asked your supplier which documentation they can actually provide, rather than assuming? Confirm specifics before committing to an order for a specific market.

Final Thoughts

The simplest way through this is to ask your buyer which standard their own supply chain requires, then work backward. Guessing wastes weeks sourcing documentation nobody asked for, while missing the one that mattered. Tell us your destination market and what your customer has specified, and we’ll confirm which documentation applies to your order before production begins.

Before You Request a Quote

Tell us your target market and we’ll confirm what documentation applies:

1. Destination market — UK/EU retail, US, direct EU import, or other
2. Whether your buyer has specified a required certification or regulation
3. Product type and liner requirements
4. Target capacity and other spec requirements

Request a quote with your target market details and we’ll confirm the relevant certification pathway for your specific order.