Wood, paper and board


Are there any restrictions on what kind of wood can be used as a raw material for food contact material?

Common wood species as such are generally considered chemically safe for contact with food. However, the way wood is processed is important, for example, if wood is coated with waxes or lacquers, its chemical safety changes and this needs to be considered when assessing the safety of the final product.


Are paper and board safe for use in contact with food? What are the regulations for assessing the safety of paper and board?

The chemical safety of the finished paper depends largely on the many different chemicals used in making the paper. There is no material-specific, special legislation for paper and board at EU level that would regulate their composition.  The use of recycled fibre in the manufacture of food contact materials involves many uncertainties that must be considered when assessing the safety of paper and board made from recycled material. Paper and board made from virgin fibre are considered to be a safer alternative for direct contact with food than paper and board made from recycled fibre.

Paper and board must meet the general requirements of EU Regulation (EU) 1935/2004 applying to all food contact materials. So that the general requirements of Article 3 of the Regulation can be found to be fulfilled, a safety reference is required against which safety is assessed. Operators themselves determine the safety reference used when there is no material-specific EU legislation.

When there is no material-specific legislation at EU level, the safety reference  used can be, for example, Council of Europe resolutions (the CoE regulation on paper and board is currently being updated) or the national provisions and official guidelines of an EU country (e.g. Germany, the Netherlands, Italy and France have national legislation on paper and board, Germany also BfR's official recommendations, which are very commonly used as a safety reference). Also the Paper and Board publication, written in cooperation between the Nordic authorities, can be used as a safety reference and for determining tests to verify safety. In addition, there are industry-specific guidelines (e.g. Cepi) that can be used.

Is it enough for the declaration of compliance for the paper to state that paper meets the requirements of Framework Regulation (EU) 1935/2004?

There is no binding legislation on the content of the declaration of compliance for paper and board products. A minimum requirement for the content in regulatory compliance is to indicate that the material complies with the requirements of Framework Regulation (EU) 1935/2004. However, an operator must be able to justify this and also to indicate which safety references the material fulfils. It is advisable to indicate separately compliance with the organoleptic characteristics in the Framework Regulation as compliance with the traceability requirements of Article 17. Indicating these matters in the declaration of compliance clearly shows that the operator is aware of those requirements and has verified them. This increases the operator's reliability.


Page last updated 4/24/2019