Home / Blog / Sustainability & Compliance
Food-Safe Dry Bag Materials
Food contact safety for a dry bag is a measured property, not an adjective. The European overall migration limit is 10 mg per dm2 of contact surface, specific migration limits for regulated phthalates run from 0.3 to 30 mg per kg of simulant, and a well-formulated phthalate-free TPU film tested against 3% acetic acid and 10% ethanol at 40 °C for 10 days typically returns overall migration below 2 mg per dm2. Anything without those numbers is a claim, not a compliance position.
This matters because dry bags are used for coolers, lunch kits, galley storage and provisioning runs, and because the materials that make a bag waterproof are exactly the materials that can migrate: plasticisers, coatings, inks and adhesive layers. This guide sets out the test framework, compares film chemistries, explains where PFAS and printed panels fit, lists the documentation to request by market, and gives a design checklist for food-contact programs.
- What food-safe actually means for a bag
- How migration testing is actually run
- Film chemistry compared
- Where PFAS enters the conversation
- Inks, coatings and printed panels
- Hardware, welds and adhesives in the food path
- Temperature and time in real use
- Rules by market
- Documentation worth requesting
- Designing for food contact: liner or direct
- Odour and taste: the test users notice
- Checklist for a food-contact bag program
What food-safe actually means for a bag
A material is treated as food-safe when laboratory testing shows that it does not transfer components into food above legally defined limits under defined conditions. The test is performed with a food simulant, at a defined temperature for a defined time, and the result is a number in milligrams. There is no certificate that simply declares a product safe.
Two limits do the work. The overall migration limit caps the total mass of anything that leaves the material, and it is set at 10 mg per dm2 of contact surface, or 60 mg per kg of simulant. Specific migration limits cap individual substances of concern, such as particular plasticisers, primary aromatic amines or heavy metals, and those limits are far lower.
A bag is more than one material. The shell, the coating, the print, the weld, the valve and the hardware can each contribute, which is why compliance has to be assessed on the finished construction rather than on the film alone. A compliant film printed with a non-compliant ink is a non-compliant article.

How migration testing is actually run
A laboratory cuts a sample of the finished material, exposes a known contact area to a simulant, holds it at temperature for a set period, then measures what has moved into the simulant. The choice of simulant and condition is dictated by the intended use: acidic foods, fatty foods, dry foods and hot foods each map to a different combination.
| Simulant | Represents | Typical condition | What it pulls out |
|---|---|---|---|
| 3% acetic acid | Acidic foods, pickles, fruit | 40 °C for 10 days | Metal ions, amines, polar additives |
| 10% ethanol | Water-based foods | 40 °C for 10 days | General-purpose aqueous migration |
| 50% ethanol | Dairy and alcoholic foods | 40 °C for 10 days | Slightly aggressive organics |
| Vegetable oil | Fatty foods, oils, cheese | 40 °C for 10 days | Plasticisers and non-polar additives |
| Tenax, dry simulant | Dry foods, bread, grain | 40 °C for 10 days | Volatiles and surface residues |
Accelerated conditions also exist for high-temperature use: 2 hours at 70 °C, 1 hour at 100 °C and, for the most demanding cases, 2 hours at 175 °C. A bag intended for a cool box does not need those, and specifying them unnecessarily will make an otherwise suitable material fail.
One subtlety separates good reporting from bad: the contact area. Migration is expressed per dm2, so a laboratory that reports only a concentration in the simulant, without the area-to-volume ratio used, has given you a number you cannot compare with a limit. Always ask for the ratio.
Film chemistry compared
| Material | Plasticiser needed | Migration risk | Typical result | Verdict for food contact |
|---|---|---|---|---|
| Phthalate-free TPU | No | Low | Under 2 mg per dm2 overall | Preferred |
| TPE and TPO | No | Low | Under 3 mg per dm2 overall | Good, check hardness grade |
| EVA | No | Low to moderate | 2-5 mg per dm2 overall | Good for liners |
| Silicone-coated fabric | No | Low | Under 2 mg per dm2, volatiles tested | Good but costly |
| Flexible PVC | Yes, typically | High | Frequently above 10 mg per dm2 | Avoid direct contact |
| PVC with non-phthalate plasticiser | Yes | Moderate | 3-8 mg per dm2 overall | Possible with test data |
The dividing line is the plasticiser. A rigid polymer can be compliant because there is little mobile material to move; a softened polymer has a deliberately mobile additive inside it, and mobile additives are what migrate. That is why the softest, most flexible films are the hardest to certify.
TPU is the comfortable answer here. It is inherently flexible without a plasticiser, it welds cleanly, and a phthalate-free grade tested against the standard simulants usually sits well under the overall limit. Our phthalate-free TPU notes cover what to look for in the formulation, and the PVC-free alternatives guide covers the wider material choice.
Where PFAS enters the conversation
Per- and polyfluoroalkyl substances are used for oil and water repellency on textiles, and they are a separate issue from plasticisers. A bag can pass migration testing and still carry a fluorinated finish on its face fabric, which is why PFAS has to be addressed as its own line item rather than assumed away by a food contact report.
For a food-contact bag the practical position is simple: specify a PFAS-free finish. Modern hydrocarbon and silicone-based durable water repellents perform acceptably for splash shedding on an already waterproof film, because the film is doing the waterproofing work and the finish only has to stop the face fabric wetting out.
The regulatory direction is also clear. Several jurisdictions are restricting PFAS in consumer textiles, and brands are removing them ahead of those deadlines to avoid holding non-compliant stock. Our PFAS-free fabric guide sets out the alternatives, and the EPA publishes current information on PFAS substances and their health assessments.
Inks, coatings and printed panels
If a printed panel can touch food, the ink is part of the food contact assessment. Pigment inks carry metal residues, some binders carry residual monomers, and a heavy print layer can crack and shed. The safe design answer is to keep print off any surface that touches food, which for a roll-top means keeping artwork above the fold line and on the outside of the panel.
Where print is unavoidable near a contact area, specify a water-based system with a food-contact declaration and ask for a migration test on the printed swatch rather than on the base fabric. A test on unprinted material says nothing about the ink.
There is also a set-off risk in storage. Bags stacked face to face in a hot container can transfer print from one surface to another, so a printed bag destined for food use should be packed with interleaving, and the print should be cured and rub-tested before release. Our water-based ink notes cover cure and rub resistance.
Hardware, welds and adhesives in the food path
A welded seam is the best outcome for food contact, because there is no adhesive layer in the joint. Two film faces fuse under heat and pressure, so the only material present is the film itself. That removes an entire category of migration concern and is one more reason welded construction is preferred for food-contact articles.
Adhesives appear elsewhere: in seam tape, in label backing, in bonded window panels and in some valve seats. Any adhesive in a contact area needs its own declaration, and the usual failure is a label applied to the inside of a bag where food rests directly against it.
Hardware matters when it is in the splash path. Stainless steel and anodised aluminium are stable; cheap plated zinc alloys can corrode in salt air and shed metal into the contents. Our hardware compliance notes and the corrosion guide both cover the grades worth specifying.
Temperature and time in real use
| Use case | Contact temperature | Contact time | Appropriate test condition | Risk level |
|---|---|---|---|---|
| Cool box with ice | 0-8 °C | Up to 3 days | 40 °C for 10 days | Low |
| Room-temperature lunch | 20-25 °C | 4-8 h | 40 °C for 10 days | Low |
| Hot food in a pouch | 60-80 °C | 1-2 h | 70 °C for 2 h | Moderate |
| Sun-heated boat locker | 40-60 °C | Days | 40 °C for 10 days | Moderate |
| Boiling water poured in | 95-100 °C | Minutes | 100 °C for 1 h | High, avoid |
| Long-term dry storage | 15-30 °C | Months | 40 °C for 10 days | Low |
Temperature accelerates migration roughly in line with the diffusion coefficient, so the difference between a cool box and a hot pouch is not a small one. Most film systems that are comfortable at 20 °C for hours become marginal at 80 °C for hours, and no soft film should be asked to hold boiling water.
Time matters as much as temperature, and it is the part people overlook in a provisioning context. A bag holding dry rice for six weeks is a long-contact application, even though the temperature is low. If that is the intended use, ask for the long-duration condition rather than the standard short one.

Rules by market
| Market | Framework | Key requirements | Documentation to request |
|---|---|---|---|
| European Union | Framework Regulation (EC) 1935/2004, Plastics Regulation (EU) 10/2011 | Overall and specific migration, declaration of compliance | DoC with test report and area-to-volume ratio |
| United States | FDA 21 CFR food contact provisions | Substance authorisation, extraction testing | Compliance letter citing the applicable section |
| Germany | LFGB, alongside EU rules | Migration plus organoleptic assessment | LFGB test report, taste and odour result |
| China | GB 4806 series | Migration and residue limits for plastics | GB 4806 test report in Chinese or bilingual |
| California | Prop 65 | Warning obligations for listed substances | Substance screening or a documented assessment |
The important point is that these frameworks do not recognise each other. A material cleared under EU rules is not automatically cleared for the US market, and a bag sold into both needs two documentary trails. That is why a bag maker should be asked which markets a compliance package covers, not simply whether a material is food-safe.
Two adjacent regimes come up in the same conversation. REACH governs substances of very high concern in articles generally, and OEKO-TEX addresses textile safety from a human-ecology angle. Neither is a food contact regulation, and neither substitutes for one. See our REACH notes and the OEKO-TEX guide for where each applies.
Documentation worth requesting
- A declaration of compliance naming the regulation, the material and the intended contact conditions.
- A migration test report with the simulants used, the temperature and duration, and the area-to-volume ratio.
- Specific migration results for phthalates, primary aromatic amines and any metal present in pigments.
- A statement on plasticiser type, or a positive declaration that no plasticiser is used.
- A PFAS declaration for the face finish, with the test method or limit stated.
- Ink and coating declarations for any printed surface near a contact area.
- Hardware grade and coating details for anything in the splash or contact path.
- Batch traceability linking the test report to the production lot shipped.
That last item is what separates a real compliance package from a folder of generic certificates. A test report for a film grade is evidence about the grade; batch traceability is evidence about the bags in the box. Insist on both.
Third-party testing is worth the fee. An in-house result is useful for development, but a report from an accredited laboratory with its scope and method stated is what a retailer, an importer or an enforcement officer will accept. Our chemical migration testing guide explains how to read one.
Designing for food contact: liner or direct
There are two clean design routes. The first is direct contact: the bag itself is built from a compliant film with compliant print and hardware, and food goes straight in. This is the right choice for cooler bags, lunch rolls and galley containers, because it is simple and it avoids a second component.
The second is a liner: a compliant inner pouch sits inside a standard waterproof shell. The shell keeps water out and carries the load; the liner handles contact. This route lets a brand use one shell across several markets with different liner specifications, and it lets the liner be replaced or washed separately.
Choose the liner route when the shell needs a feature that is hard to certify, such as a heavy camo print, reflective piping or a coated window. Choose direct contact when the bag will be washed frequently, because a removable liner adds a component that has to be cleaned as carefully as the bag. A hybrid also works well: a compliant welded liner fixed at four points inside a printed shell, which keeps the artwork away from food without introducing a loose part that can be lost on a boat.

Odour and taste: the test users notice
Users judge a food bag by smell long before they read a certificate. A film that is compliant can still carry a processing odour from extrusion or welding, and that odour transfers to bread, cheese and chocolate within hours. Organoleptic assessment, which is a formal part of LFGB testing, exists precisely because instruments cannot smell.
The practical mitigation is conditioning. Finished bags are aired before packing, often 48 to 72 hours in a ventilated space, and are packed with the mouth open rather than rolled. Adhesive-lined bags need longer than welded ones, because the adhesive continues to off-gas after the film has stopped.
Storage matters too. A bag stored rolled and sealed for six months will smell when it is opened, and that smell will go into the first load of food. Store food-contact bags loose and dry, and air them for a day before the first provisioning run of the season. A simple check at goods-in helps: open one bag from each incoming lot, smell it from 10 cm away, and hold the lot for an extra 48 hours of airing if there is any solvent or sweet plastic note.

Checklist for a food-contact bag program
- Fix the intended use first: contact temperature, contact time and food type.
- Choose a phthalate-free film and confirm it with a specific migration report.
- Specify a PFAS-free finish and say so on the specification.
- Keep print off contact surfaces, or test the printed swatch rather than the base fabric.
- Prefer welded construction so no adhesive sits in the joint.
- Confirm hardware grade and coating for anything in the contact or splash path.
- Request batch-level traceability, not a generic certificate for the film grade.
- Air finished bags before packing, and store them open and dry.
- Check the market list at the design stage; EU, US, China and California need different files.
- Compare candidate constructions across the product line and the eco-friendly range.
For retail, resort and promotional programs, this checklist becomes the compliance file that a buyer will ask for before placing an order. Assembling it at the design stage costs days; assembling it after a container has shipped costs the order. We have produced waterproof bags since 2014 in an SGS-verified 4,950 m2 facility, with a 500-piece minimum, sampling in 6 to 10 working days and bulk in 35 to 50 days, FOB Xiamen.
Two external references close the loop. Food safety in the broader sense, including how contaminants move from materials into what people eat, is documented by the WHO, and chemical substance information for the US market is published by the EPA. Neither replaces a migration report, but both explain why the limits exist.
One more practical caution for cooler and provisioning use: cold changes the bag as well as the contents. A film held at 0 °C for three days stiffens, the fold at the mouth becomes harder to roll tightly, and a closure that is not fully seated will let meltwater in. Use a film specified for low-temperature flexibility, and check the closure every time the ice is topped up.
Finally, be precise in your own copy. Food-contact compliance applies to a specified material in a specified use; it is not a property of a bag in the abstract. State the film, the test conditions and the markets covered, and let the numbers carry the claim. Our marine-safe materials guide and the Prop 65 notes sit alongside this one for programs that need the wider picture.
Frequently asked questions
Q1. Are dry bags food safe?
Only when the specific construction has been tested. Look for a migration report showing overall migration under 10 mg per dm2, specific limits met for plasticisers and metals, and a declaration of compliance naming the market regulation.
Q2. What makes a bag material food-contact compliant?
Measured migration within legal limits, tested on the finished construction with the right simulant, temperature and duration, plus declarations for ink, coating and hardware in the contact path.
Q3. Is TPU food safe?
Phthalate-free TPU is the preferred choice for food contact because it is flexible without a plasticiser and typically returns overall migration under 2 mg per dm2. It still needs a test report for the exact grade and market.
Q4. Is PVC food safe?
Generally not for direct contact. Flexible PVC relies on plasticisers, which are the substances that migrate, and overall migration frequently exceeds the 10 mg per dm2 limit. Non-phthalate formulations can pass with data.
Q5. What is the overall migration limit?
10 mg per dm2 of contact surface, or 60 mg per kg of simulant, under EU rules. It caps the total mass of anything leaving the material, and it is the headline figure on any migration report.
Q6. Which simulants are used in testing?
3% acetic acid for acidic foods, 10% and 50% ethanol for aqueous and dairy foods, vegetable oil for fatty foods, and Tenax for dry foods, usually at 40 °C for 10 days.
Q7. Do PFAS matter for food contact?
Yes, as a separate line item. A bag can pass migration testing and still carry a fluorinated water-repellent finish, so specify a PFAS-free finish explicitly rather than assuming a food contact report covers it.
Q8. Can I put food directly into a dry bag?
Yes if the bag was built and tested for contact. Otherwise use a compliant liner or a sealed food pouch inside the bag, which keeps the shell out of the contact path entirely.
Q9. Are printed panels safe against food?
Treat them as unsafe unless tested. Pigments can carry metal residues and print layers can crack and shed, so keep artwork off contact surfaces and test the printed swatch if print is unavoidable.
Q10. Does temperature change migration?
Substantially. Migration rises with temperature, so a film comfortable with a cold lunch can become marginal with a hot pouch at 70 °C. Match the test condition to the intended use, and never pour boiling water in.
Q11. What documentation should I ask a bag maker for?
A declaration of compliance, a migration report with simulants, conditions and area-to-volume ratio, specific results for plasticisers and metals, a PFAS declaration, ink declarations and batch traceability.
Q12. Is a welded seam better than an adhesive seam for food contact?
Yes. Welding fuses two film faces so no adhesive sits in the joint, which removes an entire class of migrating substances. Any adhesive in the contact path needs its own declaration and test.
Q13. Does REACH cover food contact?
Not directly. REACH governs substances of very high concern in articles generally, while food contact is covered by separate frameworks such as EU 10/2011 and FDA 21 CFR. A REACH statement is not a food contact declaration.
Q14. What about metal hardware on a food bag?
Specify stainless or anodised grades for anything in the splash or contact path. Plated zinc alloys can corrode in salt air and shed metal into the contents, which specific migration testing will pick up.
Q15. How do I stop a bag transferring odour to food?
Air finished bags for 48 to 72 hours, pack them with the mouth open rather than rolled, and store them loose and dry. Welded bags off-gas less than adhesive-lined ones, because there is no adhesive to cure.
Q16. Does China have food contact rules for bags?
Yes, the GB 4806 series sets migration and residue limits for plastic materials and articles. Bags sold in China need a GB 4806 test report, which is separate from any EU or FDA documentation you hold.
People also ask
Are dry bags safe for food storage?
They are when the specific construction has been tested: overall migration under 10 mg per dm2, specific limits met, and no untested print or adhesive in the contact path. Otherwise use a compliant liner inside the bag.
What materials are food safe for bags?
Phthalate-free TPU is the preferred option, followed by TPE, EVA and silicone-coated fabrics. Flexible PVC is the one to avoid for direct contact, because its plasticisers are exactly what migrates.
How do you test food contact compliance?
Expose a known area of the finished material to a simulant such as 3% acetic acid or 10% ethanol at 40 °C for 10 days, then measure what moved into it and compare with the legal limits.
Is TPU BPA free?
TPU does not use bisphenol A in its backbone, so a compliant grade should return no detectable BPA migration. Ask for a specific migration result rather than a general statement, since pigments and coatings can introduce other substances.
Do dry bags contain PFAS?
Some do, through a durable water-repellent finish on the face fabric. It is unrelated to migration testing, so specify a PFAS-free finish explicitly and ask for the declaration with the test method stated.
Can you put a sandwich in a dry bag?
Yes for a few hours at ambient temperature in a welded phthalate-free bag. For anything longer, warmer or fattier, use a food pouch or liner so the sandwich never sits against the shell or its print.
Need this in production volume?
QUANZHOU JUNYUAN BAGS has produced waterproof bags since 2014 in an SGS-verified 4,950 m2 facility in Fujian, China. Minimum order 500 pieces, sampling in 6–10 working days, bulk in 35–50 days, FOB Xiamen — write to service@junyuanbags.com with your spec and target market.