Using adhesive in food processing equipment is not simply a matter of selecting a strong, durable epoxy and applying it correctly. In any application where the adhesive may contact food — directly through the food contacting the adhesive surface, or indirectly through contact with food-handling surfaces that the adhesive is used to bond — regulatory requirements apply that govern which materials are permissible. These requirements are not suggestions; they determine whether the equipment can be legally operated in a food processing facility. Engineers specifying adhesives for food processing equipment need to understand which certifications and regulations are relevant to their application, what those certifications actually verify, and how to confirm that a specific product meets the applicable standard.
The Relevant Regulatory Framework
FDA 21 CFR for the United States. The U.S. Food and Drug Administration regulates food contact materials under Title 21 of the Code of Federal Regulations. The sections most relevant to epoxy adhesive in food processing equipment are:
- 21 CFR 175.105: Adhesives used as components of articles intended for use in food packaging or food contact surfaces. This section lists permitted resin types, curing agents, and additives, with restrictions on extractable components.
- 21 CFR 175.300: Resinous and polymeric coatings for food contact use.
A product described as “compliant with 21 CFR 175.105” means that its formulation uses only ingredients listed in that regulation at the permitted concentrations. It does not mean the FDA has tested or approved the specific product — FDA compliance for these materials is a manufacturer’s self-declaration that the formulation meets the compositional requirements.
EU Regulation 10/2011 (Plastic Food Contact Materials). In the European Union, plastics intended for food contact are regulated under Regulation 10/2011, which includes a positive list of permitted monomers, additives, and processing aids. Adhesives used in food contact applications in the EU must be formulated from materials on this list at the specified restrictions.
NSF International Certification. NSF provides third-party certification for a range of food safety standards. NSF/ANSI Standard 61 covers materials in contact with potable water; NSF certification for direct food contact uses different standards. NSF certification is a verified third-party assessment, distinct from regulatory self-declaration under FDA 21 CFR.
If you need regulatory compliance documentation, including 21 CFR 175.105 compliance letters and NSF certification status, for epoxy adhesive products for food processing equipment applications, Email Us — Incure provides regulatory documentation for applicable adhesive formulations.
What “Food Grade” Actually Means
The term “food grade” is not a defined regulatory category with standardized requirements. It is used loosely by manufacturers and should not be accepted without supporting documentation. A product claiming to be “food grade” may be:
- Formulated to comply with 21 CFR 175.105 (which is verifiable)
- Carrying an NSF certification (which is verifiable by certificate)
- Simply marketed with the claim without supporting documentation
When specifying adhesive for food processing equipment, require specific regulatory compliance documentation — the applicable CFR sections, EU regulation references, or NSF certificate number — not a generic “food grade” designation.
Direct Contact vs. Incidental Contact vs. No Contact
The regulatory requirements and appropriate adhesive selection differ by contact type:
Direct food contact. Adhesive surfaces that are in direct, continuous contact with food require the strictest compliance — formulation to the positive list of permitted materials and compliance with migration limits. This category includes adhesive that bonds food contact surfaces where the adhesive itself becomes a food contact material.
Incidental contact. Adhesive used on surfaces that may occasionally contact food — equipment housings, frames, structural members — is subject to less strict compliance requirements but must still be selected from formulations that do not present health risks if inadvertent contact occurs.
No food contact. Structural adhesive on equipment frames, structural members, and components that never contact food or food contact surfaces is outside the direct regulatory scope of food contact material regulations, though facility hygiene requirements (USDA requirements for meat and poultry plants, for example) may still apply to the cleanability and durability of the adhesive.
Hygiene and Cleanability Requirements
Beyond chemical compliance, food processing equipment adhesive must be compatible with the facility’s sanitation program. This requires:
Resistance to cleaning chemicals. Food processing facilities use alkaline CIP (clean-in-place) solutions, acid sanitizers, sodium hypochlorite (bleach), and sometimes steam for sanitation. Epoxy adhesive in equipment that undergoes CIP cleaning must resist these chemicals without softening, swelling, or adhesion loss.
Smooth, non-harboring surfaces. The USDA FSIS and FDA food facility requirements specify that equipment surfaces must be smooth and cleanable without crevices that harbor bacteria. Bond lines that create crevices or that allow moisture infiltration between the adhesive and substrate create potential bacterial growth sites. Void-free bond lines that are flush with or smoothly radiused at the substrate edges are required.
Temperature resistance for steam sanitation. Steam sanitation at 82°C to 100°C is used in some facilities. Adhesive must maintain integrity at these temperatures without softening or releasing from substrates.
Color visibility for inspection. Some facilities require adhesive to be a visible color — typically white or blue — so that any adhesive fragments that enter the product stream can be detected. This is an operational requirement that should be confirmed with the facility’s quality team.
Practical Application Guidance
For food processing equipment design where adhesive is used:
- Identify the contact category: direct, incidental, or no contact.
- Obtain the applicable regulatory compliance documentation from the adhesive supplier.
- Verify chemical resistance to the facility’s specific sanitation chemicals.
- Design bond lines to be flush and crevice-free, or sealed with a compliant sealant that eliminates any gap at the substrate-adhesive interface.
- Confirm temperature resistance adequacy for the facility’s sanitation temperature.
Contact Our Team to discuss food contact compliance, regulatory documentation, chemical resistance to CIP agents, and adhesive selection for food processing equipment in your facility.
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