International Bakery Tray Standards: US, EU, and Global Compliance

A bakery that buys, uses and sells within one country needs that country’s rules and nothing more. International standards become your problem in three situations: you import trays or pans made for another market, you ship food in or on materials that must meet a foreign market’s rules, or you run operations in more than one country. In each case the question is the same: does the supplier’s compliance document name the market where the tray will be used?

Two kinds of standard are involved, and they are easy to confuse: food-contact rules, which decide what a tray may be made of, and size standards, which decide whether it fits your equipment.

How the US and EU systems differ in practice

Both systems control what plastics may contact food, and both rely on lists of permitted substances. The difference a buyer sees is in the paperwork.

United States

Federal regulations permit specific substances in food-contact articles under stated conditions. For polyethylene and polypropylene, the governing section is 21 CFR 177.1520, which permits the olefin polymers it defines “subject to the provisions of this section” (21 CFR 177.1520). Those provisions set specifications for each polymer.

Two details matter to a buyer:

• Limits are section-specific. The 0.5 milligram per square inch extractives limit appears in particular sections, such as 21 CFR 175.300 on resinous and polymeric coatings (21 CFR 175.300). It is not a general limit for all plastics.
• Food type matters. FDA’s food type table lists moist bakery products, with or without free fat or oil on the surface, under a bakery products group, and lists dry solids separately (FDA food types and conditions of use). A compliance statement for dry goods does not automatically cover a moist, fatty product.

European Union

The European Commission describes Regulation (EC) No 1935/2004 as setting out “the general principles of safety and inertness for all Food Contact Materials” (European Commission on food contact materials legislation). The principles require that materials do not release their constituents into food at levels harmful to health, or change the food’s composition, taste and odor in an unacceptable way.

The Commission’s summary adds four points that matter for plastic trays:

• A positive list. Regulation (EU) No 10/2011 “establishes a Union List of substances that are permitted for use in the manufacture of plastic FCMs,” with restrictions on their use.
• Migration limits. Substances on the list carry specific migration limits, and the overall migration of all substances together may not exceed 60 mg per kg of food, or 10 mg per square decimeter of contact material.
• Good manufacturing practice. Regulation (EC) No 2023/2006 requires, for all food-contact materials, a controlled manufacturing process with documented quality assurance and quality control.
• A Declaration of Compliance. Information on composition passes along the supply chain in a Declaration of Compliance, backed by supporting documentation that must be provided to enforcement authorities on request.

The Commission’s legislation page also lists Regulation (EU) 2024/3190 on bisphenol A and other bisphenols in certain food-contact materials. If any tray, coating or container you source for the EU may involve bisphenols, ask the supplier how its declaration addresses that regulation.

The same page lists Commission Regulation (EU) 2025/351 of 21 February 2025, which amends Regulation 10/2011, the recycled plastics regulation (EU) 2022/1616 and the good manufacturing practice regulation (EC) No 2023/2006 on matters of quality control and manufacturing of plastic food-contact materials. A declaration issued before that amendment may not reflect it; ask whether the supplier’s documentation has been updated. The page also lists later, narrower amendments, such as Regulation (EU) 2025/2240 on transitional measures for certain plastic materials, so check the list again when you request documents.

EU rules are amended over time, and the Commission notes that its consolidated text of Regulation 10/2011 “may not contain all the most recent amendments.” Ask suppliers for a declaration dated after the latest amendment that affects the material.

Other markets

Outside the US and EU, each market sets its own food-contact rules and its own documentation. If you buy or ship for another market, ask the supplier for a compliance document that names that market’s regulation specifically, and confirm it with the importer or a regulatory adviser in that market. A US statement or an EU declaration is evidence about those two systems only.

Size standards are a separate question

Compliance decides what a tray may be made of; size decides whether it fits your racks, ovens and dollies. US sheet pans are sold under fraction names, while European bakery equipment can be built to metric tray sizes, so a tray made for one may not fit equipment made for the other. For equipment bought from one region for use in another, take the tray size from the equipment manual, in its own units, and check racks, rails and dollies against it before purchase.

Documents to ask for, by situation

For new materials or uncertain cases, an accredited testing laboratory can test against a named regulation. Ask the laboratory which regulation and which food simulants and conditions it tested, and keep the report with the supplier’s document.

The rule for every purchase

Accept a compliance document only if it names the market where the tray will be used, the regulation it relies on, and the food types and conditions it covers. A document that fails any of those three is evidence about some other situation, and it will not answer the question an inspector or a customer in your market asks.

Sources

• 21 CFR 177.1520, olefin polymers (govinfo)
• 21 CFR 175.300, resinous and polymeric coatings (govinfo)
• FDA: food types and conditions of use for food contact substances
• European Commission: food contact materials legislation