If you're importing PET packaging into the United States for food or beverage use, there's one regulation you need to know: FDA 21 CFR 177.1630. Get it wrong, and your shipment gets held at customs. Get it really wrong, and you're looking at recalls and fines.
Here's what you actually need to know, without the legal jargon.
What Does This Regulation Cover?
In plain English: it makes sure that nothing harmful leaches from your PET packaging into the food or drink inside. It applies to pretty much everything — PET cans, jars, bottles, cups, trays, you name it. If PET touches food, this regulation applies.
The Extraction Test (The Part That Matters Most)
The FDA doesn't just take your word that the material is safe. They require extraction testing — basically, they simulate real-world use conditions and measure whether any substances migrate from the PET into the food.
Here's how it works:
- They use food simulants — water for aqueous foods, 3% acetic acid for acidic foods, 10% ethanol for alcoholic beverages, corn oil for fatty foods.
- They test at specific temperatures and durations that match how the container will actually be used.
- They measure total extractable substances and compare against FDA limits.
If the numbers come back clean, you're good. If not, your product doesn't clear customs. Simple as that.
Temperature Ratings: Conditions A Through H
The FDA categorizes PET food contact materials into eight "conditions of use" based on temperature. This matters because a container rated for cold storage isn't automatically safe for hot-fill applications.
| Condition | Max Temperature | Typical Use |
|---|---|---|
| A | Below 40°C | Cold drinks, pre-cut fruit, refrigerated foods |
| B | 66°C | Room temperature foods |
| C | 82°C | Warm meals, hot drinks |
| D | 100°C | Hot-prepared meals, reheatable foods |
| E | 121°C | Sterilized or retort meals |
| F | Freezing | Ice cream, frozen meals |
| G | Microwave | Microwave-safe meals |
| H | Extended high temp | Industrial processing |
Here's a common mistake: someone buys PET containers rated for Condition A (cold use) and then uses them for hot-fill juice at 85°C. That's a violation, even if the container looks fine. The material wasn't tested for that temperature, and the FDA considers it non-compliant.
The Paperwork You Need
Customs doesn't care how good your product is if the documentation isn't in order. Here's what you need for every shipment:
- Certificate of Compliance (CoC) — confirms the material meets 21 CFR 177.1630
- Material specifications — resin type, additives, monomer info
- Extraction test reports — from an accredited lab, showing migration results
- Intended use declaration — what the container will actually be used for
- Letter of Guaranty — the manufacturer certifies compliance
Missing any of these, and your shipment can sit at the port for days or weeks. We've seen it happen. It's expensive and frustrating.
What's New in 2026
A few updates worth knowing:
- Mandatory GRAS notifications — manufacturers now need to formally notify the FDA about packaging materials, even if they've been used for years.
- Stricter state laws — California and others are adding requirements on top of federal rules. If you sell in multiple states, you need to track all of them.
- Enhanced traceability — FSMA Rule 204 means more documentation requirements for food contact materials in the supply chain.
How We Handle This at CHINPK
We've been exporting PET packaging to the US for over 17 years. In that time, we've had zero regulatory violations. Here's how:
- All our PET is food-grade virgin resin from certified suppliers with full batch traceability.
- We run regular extraction tests through independent labs (SGS, Intertek).
- Every shipment comes with a complete documentation package — CoC, test reports, material specs, letter of guaranty.
- We clearly label the condition rating (A through H) on every product so you know exactly what it's approved for.
If you're importing PET packaging and your current supplier can't provide all of the above, that's a problem waiting to happen. Talk to us — we can walk you through exactly what documentation you'll need for your specific product.