A purchase order for clear PET egg trays lists the SKU, cavity count, sheet gauge, carton quantity, price, trade term and ship date. The line that decides whether the shipment reaches the shelf is often missing: the compliance file. It records the resin, the test conditions and who answers a regulator. Collect it before the deposit, not after the ship sails.
Food grade is a claim, not a document
Food grade is shorthand, not a certificate issued by any EU or US authority. Regulation (EC) No 1935/2004, the framework rule for food contact materials, says a tray must not transfer constituents to food in quantities that endanger health, change composition, or spoil taste and smell. It also requires a written declaration of compliance, supporting documents for authorities, and traceability at every stage.
Article 15 adds labelling: the phrase for food contact or the glass and fork symbol, safe use instructions, the responsible business and a traceable identification. A single official EU certificate is absent from that list. Compliance is a chain from resin producer to sheet extruder, thermoformer and importer, each handing a declaration to the next. Our introduction to blister packaging places PET sheet in that chain.
The documents and what each one proves
A workable file has six parts. First, the declaration of compliance for the finished tray: issuing business and date, material identification, the rules applied, and the limits of use, meaning food types, maximum temperature and contact duration, single or repeated contact, and the highest surface area to volume ratio verified. Second, upstream declarations for resin and sheet, because an undocumented input weakens the whole chain.
Third, migration test reports from an ISO 17025 laboratory. Fourth, a good manufacturing practice statement under Regulation (EC) No 2023/2006, which requires a documented quality system, controlled processes, trained staff and traceability. Fifth, market specific evidence: in the United States, PET compliance with 21 CFR Part 177 and in particular 21 CFR 177.1630, with intended conditions of use; in the European Union, Regulation (EU) No 10/2011 for the plastic layer. Sixth, ink and label documentation where printed, covered in our guide to printing on egg trays. Ask which market the file covers, since national rules and retailer lists vary.
How to read a migration test report
Regulation (EU) No 10/2011 sets an overall migration limit of 10 mg/dm2 of contact surface for all migrating substances together, plus specific limits for authorised substances on the Union List. Testing uses simulants rather than eggs: 10 percent ethanol for aqueous foods, 3 percent acetic acid for acidic foods, 50 percent ethanol or vegetable oil for fatty foods, and Tenax for dry contact. OM2 is 10 days at 40 degrees Celsius and covers long term storage at room temperature or below; 2 hours at 70 degrees Celsius covers hot fill. A chilled tray needs a cold or ambient condition, and the report should say so.
Four checks catch most weak reports. Confirm the laboratory accreditation and date. Confirm the sample is the production article, in the same resin, gauge and print as the goods you receive. Confirm the simulant, condition and surface area to volume ratio match your use. Finally, confirm nothing changed afterwards: a new resin supplier, masterbatch, ink or recycled content means the old report no longer describes the article. Industry practice keeps the file for five to ten years.
What a factory audit adds that paper cannot
Documents describe an intention; an audit tests it. Regulation (EC) No 2023/2006 expects a quality system covering incoming materials, processes and finished goods, documented handling of non conforming product, and traceability. A video tour of the forming line and sheet store costs nothing: are sheet rolls labelled by batch, are forming parameters recorded, is the food contact surface protected, are samples retained, and can the team pull records for one carton shipped six months ago?
The BRCGS Packaging Materials standard is recognised by the Global Food Safety Initiative and asks for hazard analysis, hygiene, pest control, process control and traceability; ISO 22000 and ISO 9001 overlap. None replaces migration evidence, and a certificate does not make a SKU compliant, so read its scope. For larger orders a third party inspection helps, and our guide to incoming inspection explains defect classes and a fair claim.
When recycled content changes the file
If the tray contains post consumer recycled PET, the file grows. Regulation (EU) 2022/1616, in force since October 2022, treats recycled plastic separately because collected material may carry unknown contaminants. Mechanical PET recycling and recycling from a closed and controlled chain are the suitable technologies so far; mechanical PET processes need individual authorisation after an EFSA safety evaluation. Authorised processes appear in an EU register; new installations are audited in year one.
The buyer has one question: can the supplier name the authorised process and provide the declaration of compliance required under that regulation, including conditions on food types or uses? Recycled content has real environmental value, and our article on recyclability design explains how tray design affects recovery. It is not a reason to accept a virgin material report for a recycled article.
Seven lines to put in the request for quotation
- Request the declaration of compliance for the exact SKU, with food types, temperature, contact time and surface area to volume ratio.
- Request the upstream resin and sheet declarations that support it.
- Request an ISO 17025 migration report naming the simulant, contact condition and production sample.
- Ask which market the file covers, including national or retailer rules at destination.
- Request the good manufacturing practice statement and the scope of any BRCGS, ISO 22000 or ISO 9001 certificate.
- Ask whether the tray contains recycled PET, and if so for the authorisation and declaration under Regulation (EU) 2022/1616.
- Agree in writing that a change of resin, sheet, ink or recycled content triggers a new declaration before the next shipment.
None is exotic. They separate a supplier who shows its work from one who only describes it. Commercial terms are a separate conversation, and common technical answers sit in our blister packaging FAQ.
Quick answers
Is there an official EU certificate for food grade egg trays?
No single official certificate exists. Compliance rests on a chain: a written declaration of compliance from each business, supporting documents including migration testing, and traceability under Regulation (EC) No 1935/2004. A laboratory report alone is not a declaration, and a declaration alone is not evidence. Ask for both, and check that they describe the same article.
Do I need a separate test report for every tray size?
Not for every cavity count, but you need evidence covering the material, construction and intended conditions of each article family. A change of resin, colour masterbatch, ink, label adhesive or recycled content is a new compliance question even when the mould is unchanged. Ask the supplier to explain in writing why an existing report covers a new SKU.
How long should I keep the compliance file?
Long enough to answer a market surveillance enquiry after the goods are sold. Industry practice keeps declarations, reports and traceability records for five to ten years, with the exact period set by national rules and customer requirements. Store it with the purchase order and batch identification.
A clear tray is easy to judge by eye; its compliance is not. Browse the full range in our products section, or send us your market, food type and storage conditions and we will return the document set for your SKUs before you commit.
Cathy Zhou covers food contact documentation, testing and supplier audits for the Yelui Packaging team.