The short answer

Packaging, tableware, cookware and kitchen tools that touch food are regulated by FDA as food-contact materials. They do not need food facility registration, but the materials must be authorized for food contact — and ceramics are tested for lead and cadmium.

What exporters should watch for

📦 No facility registration — but rules apply

Facilities that only make food-contact substances or packaging do not register with FDA as food facilities. But every substance that touches food must be authorized: by an FDA regulation, a prior sanction, GRAS status or an effective food contact notification.

🍶 Ceramics and lead

Ceramic dishes, mugs and pots are tested for lead and cadmium that leach into food. Decorative items not meant for food must be clearly and permanently marked as not for food use.

🥤 Plastics and coatings

Plastic resins, coatings, inks and adhesives used in food packaging must meet the FDA rules for their use and temperature. Ask your raw material suppliers for food-contact compliance statements.

🔪 Kitchenware and appliances

Utensils, cutting boards and appliance parts that touch food follow the same authorization rules. Claims such as “antibacterial” may bring in EPA rules as well.

Common reasons shipments are stopped

  • Lead or cadmium leaching from ceramics
  • Decorative ceramics without a “not for food use” marking
  • Plastics not authorized for the food or temperature
  • Unsupported compliance claims such as “FDA approved”
  • Missing supplier documents for resins and coatings

🏢 No U.S. company to act as FSVP importer? Orionex offers an FSVP importer service for food and dietary supplements — from $80 per shipment, with the program and Qualified Individual included.

Do you need to register?

Packaging, tableware and kitchenware manufacturers do not register with FDA as food facilities. What matters is that every material touching food is authorized for that use and that the finished items pass U.S. testing (for example, lead and cadmium for ceramics). If you also make or pack food, that facility must register. Email us with your product and materials and we’ll tell you what applies.

Exporting food packaging and food-contact items to the U.S.?

Tell us your product — we’ll confirm what FDA requires, in writing, by email.

Ask by email →

Frequently asked questions

Does a packaging manufacturer need FDA registration?

No. Food facility registration does not cover food-contact substances or packaging, so a packaging or tableware factory does not register. Its materials must still be authorized for food contact, and products can be refused if they leach lead, cadmium or other unsafe substances.

Can packaging be labeled “FDA approved”?

Generally no. FDA does not approve or certify packaging. A supplier can state that its materials comply with the applicable FDA food-contact regulations, but “FDA approved” is misleading for most packaging.

Sources

Checked against FDA and other official sources on November 11, 2026. This guide is general information, not legal advice.