Compliance · Nº 01 · United States
FDA 21 CFR 175.105
FDA food-contact adhesive compliance
Applies to — Label adhesives on US food & beverage packaging
FDA 21 CFR 175.105 is the US rule for adhesives used on food packaging that do not directly touch the food — for example a pressure-sensitive label on the outside of a package, or a seam glue. The adhesive must be built from FDA-listed substances and qualify through either a functional barrier (a layer fully separating adhesive from food) or limited contact (adhesive only at seams and edges). For a label on the exterior of meat, dry-goods, or frozen produce packaging, this is the section that applies.
What it covers
The rule governs indirect food-contact adhesives — glue that is part of a food package but is not meant to touch the food itself. A pressure-sensitive label on the outside of a package, or the seam adhesive holding a carton, falls here. (Adhesives that do contact food directly are governed by a different section, 21 CFR 175.125.)
Who needs it
Any brand putting labels on US food, beverage, or supplement packaging. PSA labels on the outside of meat, dry-goods, and frozen or dehydrated produce packaging are the classic case. If your label sits on the exterior of a food package sold in the US, this is the framework your adhesive is expected to meet.
What it requires
The adhesive must be formulated from FDA-listed substances and qualify by one of two routes: a functional barrier — a material layer that fully separates the adhesive from the food — or limited contact, where the adhesive only reaches the seams or edges. Bulk adhesive that meets the rule is marked “food-packaging adhesive”. Note the FDA does not “approve” products; the manufacturer self-certifies the formula against the allowed-substance lists.
How to comply
Specify a 175.105-compliant adhesive for exterior food labels and ask your supplier for the compliance document that states it. The final fit depends on your specific contact scenario — the package structure, whether the label could migrate, and the food type — so confirm the exact case with your supplier rather than assuming a blanket “food-safe” claim. If you also sell into Europe, add EC 1935/2004 to the requirement.
Common questions
Answered
straight.
Do my food-package labels need to be FDA compliant?
If the label is on the exterior of US food, beverage, or supplement packaging, the adhesive is expected to meet FDA 21 CFR 175.105 (indirect food-contact adhesive). Ask your supplier for a compliance document — the FDA does not approve products, so the manufacturer self-certifies the formula.
What is the difference between 175.105 and 175.125?
175.105 covers adhesives that do not directly touch food (a label on the package exterior, seam glue). 175.125 covers adhesives on actual food-contact surfaces. Choose 175.125-rated adhesive for direct contact, 175.105 for exterior labels.
Does "FDA compliant" mean the FDA approved my label?
No. The FDA does not approve label products. Compliance means the manufacturer has self-certified the adhesive formula against the FDA-listed allowed substances under the relevant section. The compliance document comes from your material supplier.
General guidance — not legal advice
This is a plain-English overview to help you ask the right questions — not a legal opinion or a compliance certification. Requirements change and depend on your specific product, market, and packaging. Always confirm with your supplier’s compliance documents and, where it matters, a qualified regulatory advisor.
Official source · eCFR — 21 CFR 175.105 ↗
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