Which rules apply to sushi push-up packaging in Germany?

A careful overview of food contact materials, LFGB, migration testing, declarations of compliance and documentation for sushi push-up packaging in Germany.

Introduction

Selling sushi in a push-up tube means placing not only food, but also food contact material on the market. For B2B suppliers, the legal classification is therefore an important part of product communication. This article explains the key rules for food contact materials in Germany and the EU.

Important: This article is not legal advice. It is intended to explain the main principles relevant to sushi push-up packaging from our perspective and does not replace a product-specific review by qualified specialists, laboratories or legal counsel.

The EU Framework Regulation

The central EU basis is Regulation (EC) No 1935/2004. It requires food contact materials not to release substances into food in quantities that could endanger health, unacceptably change the composition of the food or impair odour and taste.

For manufacturers and suppliers, this means that design is not the only relevant factor. The packaging also needs to be suitably documented, tested and traceable for its intended food contact use.

LFGB in Germany

In Germany, sections 30 and 31 of the Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch (LFGB) supplement this EU framework.

In simplified terms, these provisions address the following:

Food contact articles must not pose a health risk under intended or foreseeable use.
Odour, taste or properties of food must not be affected in an impermissible way.

This is particularly relevant for a sushi push-up tube because the packaging is intended for contact with sensitive foods.

Plastic Components and Migration

For plastic components, Regulation (EU) No 10/2011 also applies where relevant. It uses a positive list of authorised substances and requires migration to be assessed under the intended conditions of use.

Key topics include:

Overall migration.
Specific migration.
Test conditions such as time, temperature and food simulants.
Declarations of compliance as part of supply chain documentation.

In a combined tube, plastic components may include lids, inner coatings, seals or contact parts. The exact requirements depend on the specific material structure.

Good Manufacturing Practice

Food contact compliance is not only about the material itself. The manufacturing process also matters. Regulation (EC) No 2023/2006 on good manufacturing practice requires materials to be manufactured under a suitable quality assurance and control system.

For B2B customers, this means that the question is not only whether a product fits the market in principle, but also whether material selection, production and quality control are considered together.

What Is Considered for the Tube

For sushi push-up packaging with several material components, the respective requirements always need to be considered together. This is especially relevant when paper, board, aluminium and plastic are combined.

Clean documentation typically involves several building blocks, including declarations of compliance, test reports, information on intended use and traceability documentation.

Sources and further reading

Conclusion

For sushi push-up packaging, design is only one part of the product. Material suitability, food contact use, migration, documentation and traceability are just as important. Keeping these topics in view and explaining them clearly creates trust and a professional foundation.