After a review of all the US Regulations that govern food and food packaging we concluded that the two most important factors for safe contact with food are the material or fiber of which the fabric is made - e.g. cotton, polyester etc., and the manufacturing process & adjuvants/additives used – e.g. oils used during knitting, dyes, softeners etc.

Both these factors have to be considered and both have to meet the following 5 basic requirements which can establish a fabric as safe for use with food:

  1. The material must be listed in one of the 21 CFR Chapter 1 sections as safe for contact with food.
  2. It must be made using substances that are considered acceptable i.e. can only be made using certain adjuvants, additives etc. that are listed in the CFRs as acceptable for use and even then only in reasonable amounts.
  3. For a coated or film-laminated fabric, the coating or film must be formulated from a material that is GRAS (Generally Accepted As Safe) or the use of which is permitted in one of the parts of 21 CFR Chapter 1.
  4. The coating/lamination must be done using an approved process (several processes are listed in the CFRs)
  5. If the fabric is waterproof it must pass test requirements for the type of food and the temperature of the storage conditions it is going to be used with. (These tests require use of solvents and, hence, cannot be used on fabrics that aren’t waterproof.) The requirements to qualify the material vary based on
    • different types of food products [i.e. for baked items, acid/non-acid, aqueous, oil/water emulsions, oils, dairy high-fat, dairy low-fat, beverages - alcoholic and non-alcoholic, etc.]
    • the container cleaning and packaging process [e.g. heat sterilization]
    • the temperature range for packing and storing [i.e. ambient room temperature, refrigerated, frozen, etc.], and
    • whether the material is intended for single use or multiple uses.

For Use With Dry Food Items

Fabrics that meet points 1-4 but have not been (and can not be) tested can be safely used for contact with and storage of dry food items. E.g. cotton fabric made in a manner that meets all other conditions can be used with dry food e.g. dry fruit, grains, flour etc.

For Use With Other Food Items (Non-Dry)

Waterproof laminated or coated fabrics (e.g. AKASoft PUL and AKASealPro) that meet the above requirements can be used for contact and storage of all types of food.

But keep in mind that not all waterproof fabrics are safe. For instance, think twice about purchasing DWR-treated fabric for use with food because fabrics that have been given a Durable Water Repellant (DWR) finish (like some ripstop nylons) may not be safe! This is due to the fact that DWR treatments are performed by applying a chemical coating on the fabric and the chemicals used may not be safe.

To be sure the fabric is suitable for use with food, ask the supplier/manufacturer the following questions:

  • Which section of 21 CFR CHAPTER 1  does it comply with? 
  • Are they sure the manufacturing process does not add any unacceptable substances to the fabric?
    E.g. what oils, additives, dyes or finishing agents were used? Where is the fabric manufactured? Have they seen the manufacturing process to ensure it is safe?
  • For a coated/laminated fabric, is the lamination/coating done using an approved process?
    E.g. Polyurethane is listed as acceptable in 21 CFR 177.1680. But that does not make all polyurethane safe. It has to be made using a resin that is listed as safe and the lamination has to be done by processes that meet the regulation – there is another section that describes acceptable manufacturing processes.
  • Has the fabric been tested at an approved laboratory for food safety and for which types of food was it tested and approved?
    Make sure they don’t mislead you by quoting it was tested to be free from lead, phthalates and BPA – those are requirements for CPSIA-compliance, not food-safety.
  • Finally, will the supplier provide a statement of assurance listing the sections of the CFR that the fabric complies with for each of the above requirements?

By completing this due diligence you can make sure you are not being misled by false claims of food safety. The FDA regulations provide us with a basis to determine food-safe fabrics and by putting all the information relative to food preparation, processing, storage etc. all in one section of the Federal regulations FDA has made it easy and accessible to everyone. Yes, the chapter is complex to navigate and extracting the required and relevant information requires moving back and forth between sections, but anyone making a claim of food safety must have done this work and must be able to provide the information to you.

EXCERPT FROM 21 CFR CHAPTER 1 SUBCHAPTER B Sec. 177.2800 Textiles and textile fibers.

Title 21: Food and Drugs
Subpart C—Substances for Use Only as Components of Articles Intended for Repeated Use

§177.2800   Textiles and textile fibers.

Textiles and textile fibers may safely be used as articles or components of articles intended for use in producing, manufacturing, packing, processing, preparing, treating, packaging, transporting, or holding food, subject to the provisions of this section.

(a) The textiles and textile fibers are prepared from one or more of the fibers identified in paragraph (d) of this section and from certain other adjuvant substances required in the production of the textiles or textile fibers or added to impart desired properties.

(b) The quantity of any adjuvant substance employed in the production of textiles or textile fibers does not exceed the amount reasonably required to accomplish the intended physical or technical effect or any limitation further provided.

(c) Any substance employed in the production of textiles or textile fibers that is the subject of a regulation in parts 174, 175, 176, 177, 178 and 179.45 of this chapter conforms with any specification in such regulation.

(d) Substances employed in the production of or added to textiles and textile fibers may include:

(1) Substances generally recognized as safe in food.

(2) Substances subject to prior sanction or approval for use in textiles and textile fibers and used in accordance with such sanction or approval.

(3) Substances generally recognized as safe for use in cotton and cotton fabrics used in dry-food packaging.

(4) Substances that by regulation in this part may safely be used in the production of or as a component of textiles or textile fibers and subject to provisions of such regulation.

(5) Substances identified in this paragraph (d)(5), subject to such limitations as are provided [...]

Read the entire section here.

Coming Next: Products that are safe for use with food (some may pleasantly surprise you!)