A food-contact compliance file is useful only when it can be tied to the finished package that will hold your salad dressing. A document headed "food grade" does not by itself show whether a particular bottle, cap, liner and dispensing valve are covered for the actual formula, filling route, storage orientation and sales market.
Start the review with the purchase specification, drawing and bill of materials beside the supplier file. The question is not whether the supplier has a PET report somewhere in its archive. It is whether the production bottle, the chosen closure and every separate contact component can be identified, matched to the right evidence and kept under change control after approval.
This is a buyer's file-review process, not a substitute for regulatory advice or laboratory testing. When there is doubt about an intended use, the responsible compliance team and qualified laboratory should confirm the applicable route before production is released.
| What you have | What to match it against | A useful review outcome |
|---|---|---|
| Supplier declaration or letter | Exact bottle, cap, liner or valve item code and material route | The document scope is traceable to the ordered assembly. |
| Migration or screening report | Food category, contact conditions, sample identity and test method | The report states what it covers and what it does not cover. |
| Drawing, quotation and BOM | Neck finish, closure construction, color, decoration and revision | Commercial and compliance descriptions do not conflict. |
| Change notice or new sample | Original approved sample and evidence file | The team knows whether a reassessment is required. |
Build a Four-Part Component Map Before Reading the Declarations
Separate the assembled package into the bottle body, the closure, any liner or seal, and the valve or dispensing insert. A bottle may be PET, HDPE, PP or glass; the closure can use a different rigid polymer and color route; a liner, induction seal or silicone valve can introduce another material and a different contact pattern. Treat each distinct component as a row in the review sheet.
For a cap-down squeeze pack, the valve, liner and sealing land may remain in prolonged contact with the dressing. For an upright pour bottle, the closure still needs review, but its contact history can be different. Record the intended consumer orientation instead of assuming that an empty-bottle report automatically covers the assembled package.
Also record color and decorative boundaries. A clear bottle and a colored bottle may not share the same material route; a cap color or masterbatch change can matter even when the external shape and thread are unchanged. Labels and inks are not automatically direct-contact components, but their placement must not enter the sealing land, internal surface or a foreseeable set-off path.
| Component row | Minimum identity to capture | Common gap |
|---|---|---|
| Bottle | Item code, polymer, color, capacity, neck finish and production revision | A generic resin statement with no connection to the finished bottle. |
| Cap or closure | Cap item code, polymer, color, seal design and supplier revision | Assuming the bottle declaration includes the cap. |
| Liner or induction seal | Layer construction, adhesive or sealant route and contact position | A closure drawing that never identifies the liner. |
| Valve or insert | Material family, part number, supplier and contact orientation | Treating a silicone or elastomeric insert as part of the cap without evidence. |
Match the File to the Dressing's Actual Contact Conditions
The product description should be specific enough for a reviewer to spot a mismatch. Record whether the dressing has a free-oil phase or is an emulsion, its acidity or pH if available, alcohol content if relevant, fill temperature, shelf-life target and expected storage. This information is not a request to select a test method by guesswork; it is the minimum context a laboratory or compliance reviewer needs to determine whether the stated evidence is relevant.
A cap-down format deserves separate attention because product can remain against the liner, valve and sealing land for much of its shelf life. Likewise, warm filling, slow cooling and warm distribution can create a different exposure history from an ambient cold-fill product. Compare that history with the conditions named in the report instead of assuming that the headline material is enough.
For EU plastic materials, EU No 10/2011 sets specific rules on composition and migration testing, including the use of food simulants and standardized time-temperature conditions. The file reviewer should record the conditions actually stated in the evidence and let the responsible laboratory decide whether those conditions cover the finished product.
| Commercial fact to provide | Why it changes the review | Do not conclude |
|---|---|---|
| Oil phase and acidity | A multi-phase dressing may need more than one relevant food-contact scenario. | That any one simulant is a universal shortcut. |
| Maximum filling temperature | Warm filling can change exposure and mechanical package behavior. | That an ambient-storage statement covers a warm-fill route. |
| Shelf life and distribution | Contact duration and foreseeable temperature history affect scope. | That a short screen automatically covers long-term storage. |
| Upright or cap-down use | Closure, liner and valve contact can change materially by orientation. | That an empty-bottle report covers the cap-down assembly. |
Read Migration Reports as Test Records, Not Pass Certificates
A migration report should let a later reviewer reconstruct what was tested. Check the report number and date, laboratory identity, sample description, material or component identity, conditioning, simulant or food, contact time and temperature, method, reporting limit, result and acceptance basis. If any of those fields is missing, ask the laboratory or supplier to clarify the scope in writing.
Overall migration, specific migration and targeted extractables work answer different questions. A report may be appropriate for the tested component and still not answer whether another cap liner, colored masterbatch or elastomeric valve is covered. Keep the result beside the component map rather than treating it as a blanket approval for a product family.
Food-contact evidence is also different from finished-package performance validation. Torque retention, cap-down leakage, valve recovery, odor or taste review and dispensing performance may need their own checks with the actual dressing. A compliant material file cannot by itself prove that the assembled package will seal or dispense correctly.
| Report field | Why it matters | Red flag |
|---|---|---|
| Sample description | It connects the result to the bottle, cap, liner or valve you intend to buy. | Only "plastic sample" or no part identification. |
| Contact conditions | It shows the test scenario used for the result. | No simulant, food, time or temperature stated. |
| Method and reporting limit | It explains what the laboratory measured and how far the result can be interpreted. | A result with no method or analytical boundary. |
| Conclusion and scope | It identifies the applicable criterion and any limitation. | A generic "food grade passed" statement. |
Freeze the Approved File and Define Change Triggers
After approval, create a short controlled record that connects the purchase specification to the reviewed evidence: bottle and closure item codes, material and color route, liner or valve construction, supplier, report numbers, intended use and the review date. Retain a labelled physical sample or clear assembly photographs with the file where practical.
Set change triggers before reorders begin. A new bottle color, masterbatch, resin source, cap supplier, liner construction, valve formulation, neck finish, fill temperature or sales market can move the order outside the original review. The correct response is not necessarily a full retest; it is a documented coverage decision from the responsible supplier, laboratory or compliance owner.
A controlled component matrix is a relevant manufacturing advantage because it prevents buyers from relying on the wrong report after an apparently small commercial substitution. The strongest supplier response is a scoped file and an honest statement of what needs further confirmation, rather than a broad compliance promise.
- Freeze the final bottle, cap, liner and valve item codes before purchase approval.
- Retain the final color and material route, not only the nominal polymer name.
- Keep the report scope, intended-use assumptions and sales-market requirement with the purchase file.
- Require a written review when a material, supplier, color, closure or use condition changes.
A One-Page Buyer Checklist Before You Release the PO
Before releasing a purchase order, compare the final quotation, drawing and sample against the file one more time. The objective is a simple yes, no or clarification decision for every component. If the supplier cannot identify which file covers a specific liner or valve, leave that row open rather than treating a broader bottle report as proof.
Send the final assembly description, dressing profile, fill temperature, shelf life, storage orientation and destination market to the supplier with the request. This gives the supplier a concrete basis to assemble the correct component documents and to identify where laboratory or regulatory review is still needed.
| Pre-PO check | Yes / no decision |
|---|---|
| Every direct-contact component has a part identity and material route. | |
| Each declaration or report can be matched to that component and supplier route. | |
| The stated food-contact use matches the product, fill, shelf life and orientation. | |
| The file records limitations, exclusions and any outstanding confirmation. | |
| Change triggers are agreed before repeat production. |
FAQ: Reviewing a Salad Dressing Food-Contact Compliance File
Can one PET bottle report cover the cap, liner and valve? Only when the report or supporting documentation explicitly identifies and covers those components. A closure, liner or silicone valve may have a separate material and contact profile.
Does an FDA reference prove that any supplier's component is acceptable? No. FDA explains that authorizations can depend on the substance, specifications, conditions of use and, for an FCN, the named manufacturer. Match the component and source to the evidence.
Does a Declaration of Compliance prove the finished package will not leak? No. A food-contact file and mechanical package validation answer different questions. Use the actual dressing to verify torque, seal, cap-down leakage and dispensing performance.
When should a buyer reopen the file? Reopen it when the material source, color, cap, liner, valve, bottle design, intended use, fill conditions or destination market changes in a way that may fall outside the original scope.
Request a Component-by-Component File Review
For a practical pre-PO review, provide the bottle and closure item codes, drawing or sample, material and color route, liner or valve construction, dressing description, fill temperature, shelf life, storage orientation, destination market and the documents already on hand. The result should be a component matrix that separates evidence already matched to the assembly from items that need clarification.
This approach helps the buyer release the correct sample and document request without representing a generic certificate as approval for a different finished package.