Food-Contact Compliance for Coated Paper in India: FSSAI, IS 15495, and What Migration Testing Requires

Coated paper in food contact in India is governed by the Food Safety and Standards (Packaging) Regulations, 2018, and those regulations contain no standard written for coated paper. Compliance is assembled from the general paper clauses, the multilayer rule that regulates whichever layer touches the food, IS 15495 for the ink, and a certificate of conformity from a NABL-accredited laboratory.

That is the whole difficulty in one sentence. A coater applying a dispersion barrier, a biopolymer, a polyethylene extrusion layer or a silicone to a base paper is producing something the Indian regulation never describes directly, so the compliance answer depends on reading four separate clauses together and then deciding, coating by coating, which test a laboratory should actually run.

This is written for the coating or converting technologist who has to produce the compliance file, and for the procurement head who has to decide whether the file a supplier sent is worth anything. It covers what FSSAI does and does not say about coated paper, which layer the regulation regulates, when migration testing to IS 9845 is mandatory and when it is merely sensible, what IS 15495:2020 requires of the ink, how the German and American paper rules fill the gap for export, and what changed in August 2026.

Does FSSAI have a standard written for coated paper in food contact?

No. Schedule I of the Food Safety and Standards (Packaging) Regulations, 2018 lists six Indian Standards for paper and board in contact with food, and none of them is a specification for a barrier-coated or functionally coated paper. The list covers grease proof paper (IS 6622), vegetable parchment and grease proof paper and aluminium foil laminate (IS 7161), aluminium foil laminates for packaging (IS 8970), general purpose packing or wrapping paper (IS 6615), uncoated folding box board (IS 1776) and corrugated fibre board boxes (IS 2771).

What the regulation does say about paper is general. Regulation 4(1) requires that paper and board material intended to come into contact with food “shall be of uniform formation, thickness and substance”, “shall be free from visible specks, grease marks, cuts, pinholes and other blemishes”, and that paper meant to be in direct contact with food “shall be of food grade and shall be free from contaminants”. Sub-clause (d) then points to Schedule I for materials used in containers for packing or storing food. Food grade itself is defined in Regulation 2(1)(b) as material “made of substances which are safe and suitable for their intended use, and shall not endanger human health or result in unacceptable change in the composition of the food or organoleptic characteristics”.

The only coating the regulation names at all sits in a note under Schedule I: “The wax used for coating the paper or board shall be paraffin wax conforming to Type I of IS 4654.” That is the full extent of FSSAI’s guidance on a coated paper. Wax has a standard. A dispersion barrier, a biopolymer layer, a silicone release coat or an extrusion coat has none.

The clause that turns this silence into a workable rule is the proviso to Regulation 3(1): “where Indian Standards are not available, then relevant International Standards may be complied with.” That proviso is the legal basis on which most coated-paper compliance files in India are actually built, and it is why the German and American paper rules discussed later in this article appear in Indian test reports. A converter reading it as permission to skip testing is misreading it. It says which standards may be used where India has none; it does not say that no standard need be met. Our earlier note on food-grade paper bag compliance in India covers the uncoated bag case; this article is about what changes once a coating goes on.

Which layer of a coated paper does FSSAI actually regulate?

The layer that touches the food. Regulation 3(12) states that “in case of multilayer packaging the layer which comes in direct contact with food or layers likely to come in contact with food shall meet the requirements of packaging materials specified in Schedule I, II and III of these regulations.” A coated paper is, in the regulation’s own vocabulary, a multilayer material, defined in Regulation 2(1)(c) as packaging “composed of two or more layers of same or different types of packaging materials”.

For a coater this is the most useful clause in the regulation, because it means the compliance question is answered by the coating and its position, not by the base paper alone. If the coating faces the food, the coating is the regulated layer. If the coating faces outward and bare paper touches the food, the paper is the regulated layer and the coating falls under the general compatibility requirement in Regulation 3(13), which asks only that listed materials “be compatible with their intended use as a packaging material so as not to alter the quality and safety of the food product”.

The practical consequences sort into four cases, and each one sends the laboratory down a different route.

Where the coating sits decides the regime before the chemistry does. A coater who moves a barrier from the inside of a structure to the outside has, in FSSAI terms, changed which schedule applies without changing a single raw material. There is nothing improper in that. The regulation is written around contact, so the file should record the layer order as a design choice, with a diagram, rather than leave an auditor to infer it.

What migration testing does FSSAI require, and when does it apply to a coated paper?

FSSAI mandates migration testing for plastic materials, not for paper. Regulation 4(4)(b) requires that “all packaging materials of plastic origin shall pass the prescribed overall migration limit of 60 mg/kg or 10 mg/dm² when tested as per IS 9845 with no visible colour migration”, and 4(4)(c) adds specific migration limits for seven metals. There is no equivalent clause for paper, so a coated paper is migration-tested under FSSAI only when its food-contact layer is a plastic.

The vocabulary is defined precisely. An overall migration limit is “the maximum permitted amount of non-volatile substances released from a material or article into food simulants” (Regulation 2(1)(d)), and a specific migration limit is “the maximum permitted amount of a given substance released from a material or article into food or food simulants” (Regulation 2(1)(i)). IS 9845:1998, the method the regulation names, exposes the material to food simulants chosen to represent the food type, among them distilled water, 3 per cent acetic acid and n-heptane, for a set time and temperature, and weighs what came out.

Source: Table 1, Food Safety and Standards (Packaging) Regulations, 2018, requirement for specific migration limits of substances from plastic materials intended to be in contact with articles of food.

Where this bites a coater is the polyethylene extrusion-coated paper, the PE-lined cup stock and the paper-plastic laminate. In each of those the plastic is the contact layer, Regulation 3(12) routes it to Schedule III, and the overall migration test to IS 9845 becomes mandatory rather than optional. The base paper’s own properties matter to that result only indirectly, but they do matter, because a porous or poorly formed base changes coat weight and coverage, and pinholes in the plastic layer expose paper to the simulant. That link between the sheet and the coating on it is explained in our note on porosity and air permeability in coating base paper.

The middle case, and the awkward one, is the dispersion barrier or biopolymer coating that faces the food. It is not a plastic under Schedule III, and it is not one of the six paper standards under Schedule I. FSSAI mandates no migration test for it, and Regulation 3(14) still requires the food business operator to “obtain the certificate of conformity issued by NABL accredited laboratory against these regulations for the packaging material which comes in direct contact with food”. A laboratory asked to certify against regulations that name no method for the material in front of it will generally run overall migration to IS 9845 anyway, using the Regulation 3(1) proviso as the justification, and report the result against the 60 mg/kg figure as a reference value. That is defensible practice, and it should be described in the file as exactly what it is: a test run by analogy, not one the regulation prescribes for paper.

One honest limitation belongs here. Passing an overall migration test on a coated paper tells you that the total non-volatile material released into a simulant was below a threshold. It says nothing about any particular substance of concern in the coating formulation, or about mineral oil or fluorinated chemistry, and it is silent on odour and taint. Those questions need targeted tests that FSSAI does not specify at all, and a supplier who offers an IS 9845 pass as a complete answer is offering a partial one.

What does IS 15495:2020 require of the ink on a coated paper?

Two FSSAI clauses govern the ink, and both are short. Regulation 3(9) requires that “printing inks for use on food packages shall conform to IS: 15495”, and Regulation 3(10) that “printed surface of packaging material shall not come into direct contact with food products”. Neither clause distinguishes coated from uncoated paper, so both apply in full to a printed barrier structure.

IS 15495:2020, Printing Ink for Food Packaging, Code of Practice (First Revision), replaced the 2004 edition in June 2020. The revision moved toluene, phthalates and titanium acetylacetonate onto the exclusion list in Annex A, under solvents, plasticisers and various compounds respectively, and it sets a combined heavy-metal ceiling: the sum of lead, cadmium, mercury and hexavalent chromium in the ink is not to exceed 100 parts per million. It also carries a design instruction that matters on a converting line: printing should not occur in areas which, by folding, come into contact with food.

For a coater the ink question has a specific shape that the bag or carton converter does not face. On a reel-fed coated structure the printed face is wound against the coated face for the whole life of the reel, so set-off, the transfer of ink from the printed surface to the surface it is wound against, is a food-contact pathway even though the printed side itself never touches the food. Reverse-printed structures, where the ink is trapped between paper and a laminating layer, are the other case, and there the ink’s solvent retention and the laminating adhesive both need to appear in the file. Our companion piece on ink adhesion and substrate preparation for paper printing deals with the press-side variables; the compliance-side point is simpler. The ink supplier’s IS 15495 declaration covers the ink as supplied. The converter’s file has to cover the ink as printed, cured and wound, and only a set-off or migration test on the finished reel does that.

It is worth settling in writing who holds which piece of evidence. FSSAI puts the duty on the food business operator, meaning the brand owner filling the pack, through Regulations 3(1) and 3(14). The brand owner will push that duty back down the chain in a supply agreement, and a converter who cannot produce an ink conformity declaration, a layer diagram and a NABL test report against the finished structure will be asked to pay for one.

How do BfR XXXVI, the EN methods and FDA 21 CFR 176.170 fill the gap for coated paper?

They supply what FSSAI lacks: named limits and named methods written for paper, coated paper included. Under the Regulation 3(1) proviso a converter may comply with them where India has no standard, and any converter selling into a multinational brand owner or an export market will be asked for them regardless. The three regimes differ enough that they cannot substitute for one another.

Two features of the German document deserve a closer look because they are the ones most often missed in Indian files. The first is footnote 3 to paragraph 7, which states that the lead and cadmium extract testing “is not necessary for paper and paperboard intended for contact with dry and at the same time non-fatty foodstuffs (e.g. flour, semolina, rice, breakfast cereals, breadcrumbs, sugar and salt)”. A dry-food liner therefore carries a lighter BfR test burden than a wrap for a fatty product, a distinction we relied on in the dry food liner paper note. The second is paragraph 4: “the finished paper or paperboard must have no preserving effect on the foodstuffs with which they come into contact.” Several coating additives and slimicides used in papermaking would fail that test at the wrong dose, which is why the positive list matters as much as the migration numbers.

The American rule works differently again. It does not ask what migrates in total; it asks whether every component of the food-contact surface is a listed substance, and then applies the 0.5 milligram per square inch extractives ceiling under conditions matched to the food type and use temperature. A dispersion coating built from a polymer listed under 176.170 can be compliant in the United States and still need a full BfR work-up for Germany. The two files can share test data, but they are built on different logic, and one cannot be handed over in place of the other.

What changed for coated paper compliance in 2026?

Three things, and only one of them is Indian. The Food Safety and Standards (Packaging) Amendment Regulations, 2026 were published in the Gazette of India on 10 August 2026 and came into force on publication. The amendment added pan masala as a new entry under Schedule IV, the regulation’s list of packaging materials by product category, and the permitted materials are paper, paperboard, cellulose, naturally derived materials, tin and glass, provided they are free from plastic, synthetic polymers, laminates, aluminium foil and metallised layers. Polyethylene, polypropylene, polyester, polyvinyl chloride and other synthetic polymers, copolymers and laminates are named as not permitted for that category.

For a coater the product matters less than the drafting. Schedule IV had always been introduced by Regulation 5 as “an indicative list not restricting the use of any other packaging material complying with the specified standards”. The August 2026 entry is written as a restriction, and it is the first time FSSAI has defined a category by what the packaging must be free of rather than by which standard it must meet. Every barrier chemistry that is a synthetic polymer, and every metallised or foil-bearing structure, is outside that category. A coated paper aimed at it has to be built on a coating that can honestly be described as free from plastic and synthetic polymers, and the compliance file has to say so in those words. Whether that pattern spreads to other categories is unknown, and nobody should be told it will; what is known is that the drafting template now exists.

Outside India, Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026 and sets limits in Article 5 for food-contact packaging of 25 parts per billion for any single PFAS and 250 parts per billion for the sum of targeted PFAS, with a 50 parts per million ceiling on total PFAS including polymeric species. India sets no equivalent limit, so an Indian coater exporting a fluorochemically treated grade to the European Union is governed by the destination rule and a domestic sale is not. The third change is procedural: Germany’s BfR opened a consultation in April 2026, closing on 30 June 2026, to consolidate Recommendations XXXVI, XXXVI/1, XXXVI/2 and XXXVI/3 into one document and add CAS numbers, with no new substances, limits or technical requirements proposed. A converter holding a current BfR file does not need to redo it on that account.

How should a coater assemble a compliance file for a coated paper?

In a fixed order, because each item determines which tests the next one needs. The following sequence produces a file that survives a brand owner’s audit and, more usefully, tells the laboratory what to run.

1. Draw the layer diagram and mark the food-contact face. Base paper, each coating, any print, any adhesive, and which face is inside. Regulation 3(12) makes this diagram the document everything else hangs on.
2. Identify which FSSAI schedule governs the contact layer. Schedule I for bare paper, Schedule III for a plastic layer, the Regulation 3(1) proviso and a named international standard for anything else.
3. Collect the base paper’s own conformity. If the base is a Schedule I grade, its IS number and the mill’s test certificate; if it is a coating base with no Schedule I standard, the mill’s declaration against BfR XXXVI or an equivalent, and the test report behind it. Our guide to specifying a release liner base paper sets out what a base-paper certificate should contain.
4. Collect the coating chemistry’s food-contact status from the chemical supplier: FDA listing under 21 CFR 176.170 or 176.180, BfR XXXVI positive-list status, or a Regulation (EU) 10/2011 declaration for a plastic layer. Ask for the document, not the sentence in the datasheet.
5. Obtain the ink supplier’s IS 15495:2020 conformity declaration for each ink and varnish, and note the heavy-metal sum and the excluded-substance statement on it.
6. Commission the NABL-accredited laboratory test against the finished structure, not the components. Overall migration to IS 9845 where the contact layer is plastic, or by analogy where it is a non-plastic coating; a cold water extract with lead and cadmium, an antimicrobial transfer test and a sensory test where the customer is applying BfR; a set-off test on the wound reel where the structure is printed.
7. Run the sensory test whatever the regime, because an odour or taint complaint is the most common way a coated paper actually fails in the market and none of the Indian numeric tests would have caught it.
8. Keep the file per structure and per reel batch, and date it. Regulation 3(14) attaches the certificate to the material used, and a certificate for last year’s coating formulation does not cover this year’s.

Step six is where the cost sits, and it is the step most files skip. A stack of component declarations describes what went into the structure. Only a test on the structure describes what comes out of it, and the regulation’s certificate of conformity is written about the material “to be used”, meaning the finished thing. Definitions for the test terms above are in the paper converter glossary; the sachet case, where the contact face and the seal face are the same coated surface, is worked through in our sachet paper substrate note.

Where a coating base paper fits in a food-contact compliance file

A coating base paper does not come with a food-contact compliance file, and it cannot, because the file belongs to the finished structure and the base is one layer of it. That is the first limitation to state. A base paper supplier can give you a mill certificate for the sheet, a statement of what went into it, and a declaration against a paper recommendation such as BfR XXXVI. It cannot tell you whether your coating, your ink and your layer order will pass, and a base supplier who claims otherwise has not read Regulation 3(12).

The second limitation is that a base paper contributes to compliance mainly by not causing a failure. It can fail a file through contaminants, through a production aid that is not on a positive list, through pinholes that expose the sheet behind a barrier, or through a formation that leaves the coating uneven. It cannot pass a file on its own. What a good base does is remove those failure routes so that the compliance outcome depends on the chemistry you chose, which is the variable you control.

Pakka is developing flexC base, a coating base paper in the 40-60 GSM band, available bleached and unbleached, intended as a substrate for barrier chemistries including silicone, biopolymer and plastic coatings. The eight applications named for it are confectionery wraps, snack pouches, sachets, medical packaging, seed packs, release liners, dry food liners and tea pouches, and most of those are food-contact structures where the questions in this article apply directly. These details are disclosed in Pakka Limited’s Investor Presentation for Q1 FY2026-27, filed on 18 August 2026 (BSE 516030 / NSE PAKKA). It is a development programme rather than a shelf product, and it carries no published performance or compliance data, so no migration result, extract value or food-contact approval should be attributed to it.

Two names need keeping apart. flexC base is the coating base paper described here, bought by a coater or converter who will build the food-contact structure on it. flexC is a different product: a finished compostable flexible-packaging laminate that Pakka already supplies to brand owners, with its own published specifications and its own compliance file. A converter assembling the file described in this article wants the first. A brand owner buying a ready structure wants the second, and should ask for the second’s file, not the first’s.

Where a base paper does earn a place in a coater’s compliance thinking is at step three of the sequence above. A coating base supplied with a full raw-material and production-aid declaration, written against a recognised paper recommendation, shortens the laboratory’s work and removes the base from the list of suspects if a structure fails. That is a reasonable thing to ask any base paper supplier for, and a reasonable thing to refuse to buy without. Our comparison of glassine, SCK and CCK as release liner bases shows what such a declaration looks like for the three incumbent grades.

Frequently asked questions

Is coated paper food grade in India by default?

No. FSSAI requires any material in direct contact with food to be of food grade quality (Regulation 3(2)), defines food grade in terms of safety and suitability, and attaches a NABL certificate of conformity to the material used (Regulation 3(14)). A coated paper has to earn that certificate on its finished structure. There is no Indian Standard that a coated paper can simply be declared against.

Does FSSAI require migration testing for paper packaging?

Not for paper as such. The overall migration limit of 60 mg/kg or 10 mg/dm² to IS 9845 and the Table 1 specific migration limits in Regulation 4(4) apply to plastic materials. A coated paper falls under them only when its food-contact layer is a plastic, through the multilayer rule in Regulation 3(12). For non-plastic coatings, laboratories commonly run IS 9845 by analogy under the Regulation 3(1) proviso.

What is the difference between IS 15495:2004 and IS 15495:2020?

The 2020 first revision of the printing ink code of practice added toluene, phthalates and titanium acetylacetonate to the Annex A exclusion list and set a combined limit of 100 parts per million for lead, cadmium, mercury and hexavalent chromium. FSSAI’s Regulation 3(9) references IS 15495 without a year, so the current edition is the one a laboratory or auditor will apply.

Which international standard should an Indian coater use for a coated paper?

The one the destination market or the customer’s own standard requires. BfR Recommendation XXXVI is the reference most multinational brand owners apply to paper and board, and its paragraph 10 covers coated and multilayer materials explicitly. For the United States, 21 CFR 176.170 and 176.180 apply. FSSAI’s Regulation 3(1) proviso permits either to be used in India where no Indian Standard exists.

Does a silicone release coating need food-contact testing?

Usually not, because in a normal release-liner structure the silicone faces the adhesive or the process and the paper face is the only side that could contact food, if any side does. The file should say that in words and show it in the layer diagram. If a silicone-coated surface could contact food, for example in a baking or bakery release application, the silicone falls outside the paper rules and needs its own assessment.

Last reviewed: September 2026.

Building a compliance file on a coating base? Pakka’s flexC base programme covers the 40-60 GSM band in bleached and unbleached, for coaters and converters constructing their own barrier and food-contact structures. If you would like to discuss a trial, get in touch with a flexC base trial enquiry and tell us the application, the coating chemistry and the market the finished pack is sold into. Technical brochures for our paper and packaging range are on the resources page, and general enquiries reach us through the same contact page.

Sources

• Food Safety and Standards Authority of India, Food Safety and Standards (Packaging) Regulations, 2018 (Compendium, Version II, 1 February 2022), Regulations 2, 3, 4 and 5, Table 1, Schedules I, III and IV
• Bureau of Indian Standards, IS 15495:2020, Printing Ink for Food Packaging, Code of Practice (First Revision); revision summary in PrintWeek India, “Stringent regulation for ink as per IS 15495:2020”
• Bureau of Indian Standards, IS 9845:1998, Determination of Overall Migration of Constituents of Plastics Materials and Articles Intended to Come in Contact with Foodstuffs, Method of Analysis
• German Federal Institute for Risk Assessment (BfR), Recommendation XXXVI, Paper and Board for Food Contact, as of 1 February 2023
• US Code of Federal Regulations, 21 CFR 176.170, Components of paper and paperboard in contact with aqueous and fatty foods
• European Union, Regulation (EU) 2025/40 on packaging and packaging waste, Article 5, applicable from 12 August 2026
• Business Today, “FSSAI bans plastic, aluminium foil packaging for pan masala; only paper, tin and glass allowed now”, 12 August 2026, reporting the Food Safety and Standards (Packaging) Amendment Regulations, 2026, Gazette of India, 10 August 2026
• knoell, “Germany’s BfR revises food contact paper and board recommendations: what to know before the June 2026 deadline”
• Pakka Limited, Investor Presentation Q1 FY2026-27, filed 18 August 2026 (BSE 516030 / NSE PAKKA)

Browse all Pakka articles.