April 25, 2025
Jump to:
When it comes to food safety, it isn't just about clean hands, sanitized cooking areas, and proper food storage. For many businesses in the food and beverage industry, it is about food-safe packaging materials as well. And that often includes using an adhesive that is approved for food packaging.
If you are not sure where to begin, we want to help. We explain a bit more about the FDA 21 CFR 175.105 regulations and highlight some products that are indirect food contact safe adhesives that may meet your needs.
What is FDA 21 CFR 175.105?
Regulation 21 CFR 175.105 refers specifically to Title 21, Chapter I, Subchapter B, Part 175, Subpart B "Adhesives" from the Food and Drug Administration (FDA).
The FDA is a federal agency responsible for protecting public health by regulating various types of products, including food, drugs, biologics, medical devices, cosmetics, veterinary products, tobacco products, and more. 21 CFR 175.105 focuses specifically on indirect food contact adhesives in food packaging. It includes criteria regarding formulation as well as how these adhesives should be used in food packaging to meet the proper safety standards.
Indirect Food Contact Adhesives Explained
Let's break this down a bit more by taking a step back. To start, we should note how the FDA defines a related term. A food additive is "any substance the intended use of which results or may reasonably be expected to result, directly or indirectly, in its becoming a component or otherwise affecting the characteristic of any food."1
There are three types of food additives, including direct, secondary direct, and indirect. They can pertain to substances used in various steps in the production process, including the manufacturing, preparation, processing, packing, transporting, and holding of food. Food packaging and its components (like adhesives) are considered indirect food additives that do not come into direct contact with the food itself. These indirect food contact adhesives must meet the FDA 21 CFR 175.105 regulations for adhesives.
Examples of applications where FDA indirect food contact adhesives are needed include:
-
Between layers of laminated food packaging
-
For labels that go on food jars or bottles
-
To bond agents in cartons or flexible film wraps
175.105 Adhesive Regulations for Food Packaging Manufacturers
The burden of compliance for FDA 175.105 adhesive regulations typically falls on the packaging manufacturer instead of the adhesive manufacturer.
Simplifying FDA regulation 21 CFR 175.105, adhesives can safely be used in the packaging, transporting, or holding of food if they meet the following conditions:
1. The adhesive is prepared from one or more approved substances.
2a. The adhesive is separated from the food by a functional barrier.
2b. OR The amount of adhesive that comes in contact with the packaged food cannot exceed the limits of the FDA's Current Good Manufacturing Practices (CGMPs). (There are different requirements regarding dry goods versus fatty and aqueous foods.)
3. The finished adhesive container must include a label that reads, "food-packaging adhesive."2
Along with safe use, there are also very specific, technical requirements regarding the formulation of these FDA-compliant glues for indirect food contact. In simpler terms, optional substances used in the formulation of FDA 175.105 adhesives may include some of the following:
-
Substances generally recognized as safe for use in food or food packaging
-
Substances with prior sanction or approval that are used according to the specific conditions outlined by those sanctions or approvals
-
Flavoring substances permitted for use in food so long as they are volatilized from the adhesives during the packaging fabrication process
-
Color additives approved for use in food
-
Substances approved by other regulations in the Food for Human Consumption subchapter so long as they meet any specific regulations outlined for them2
These are just a simplified and summarized version of the FDA 175.105 Adhesives section. Regulations can also change, and substances are subject to limitations. To ensure you remain compliant, reference the current FDA 21 CFR 175.105 adhesive regulations at the Code of Federal Regulations. It is also important to note that pressure-sensitive adhesives for indirect food contact have a separate subset of regulations under 175.125.
See What We Suggest
Feeling a little lost? That is okay. At Gluegun.com, we carry various food-safe glues (and even some food-grade tapes) that meet the FDA indirect food contact regulations for adhesives. To help you determine the best option for you, our team shares a few notable products that may be worth investigating and testing with your application.
General Purpose Packaging Applications
For a general-purpose FDA 175.105 adhesive, the ASURE CC9210 hot melt adhesive is a good option to try for various packaging applications, especially for case and carton sealing. It can be applied at a standard temperature and has great thermal stability to reduce adhesive charring and related maintenance problems. The low odor formulation also creates a better environment for workers.
Low Temperature Packaging Applications
The ASURE CC0530 low temperature hot melt adhesive is also great for general purpose packaging applications but has a lower application temperature at 250°F. It provides excellent adhesive to difficult board stock, including recycled and high-performance liners. It is also fast setting, so it is suited for high-speed applications.
Biodegradable Options
If your company is looking for a more sustainable indirect food contact glue, we have a few different biodegradable hot glues available for purchase.
For automated or high-speed packaging lines, try Tecbond 110B biodegradable hot melt pellets. They are not only certified biodegradable to ASTM D6400 standards, but also they can operate at lower temperatures to reduce energy use.
For manual packaging applications, Tecbond 214B biodegradable hot glue sticks may be a better option. They meet FDA175.105 packaging adhesive regulations. They are also 45% bio-based and designed to break down naturally when exposed to UV light, heat, and oxygen.
Industrial Tape
An FDA 175.105 tape, the 3M VHB LVO tape is unique in that it is designed more for industrial applications versus packaging applications and safe for indirect food contact. It can be used to bond cookware, large appliances, sinks, benchtop cooking equipment, food preparation tables, and much more.
Regulations can change, so it is important to check that the adhesive is currently still meeting these regulations and your needs. Need help determining an FDA 175.105 adhesive that is compliant and right for your application? Reach out to an adhesives expert for more information and a personalized product recommendation.
Sources:
1. U.S. Food & Drug Administration (2018). Food Ingredient & Packaging Terms
2. National Archives Code of Federal Regulations (2025). § 175.105 Adhesives
