Customer compliance statements, drafted from your suppliers' own letters.

A brand's quality team wants paperwork on a printed carton or a laminated pouch: its FDA food contact status, a toxics-in-packaging certificate, a PFAS statement, sometimes the FSC claim. Your quality lead takes the item apart into board or film, resin, ink, coating and adhesive, pulls each supplier's latest letter, checks it reaches the food and use the brand named, and writes the statement. One missing letter holds the whole request.

For the test, AI works on copies of requests you already answered and drafts each statement with a source on every line: which supplier letter, its date and what it covers. A material with no current letter, or a letter that stops short of the brand's food or use, is listed for the person who signs. No customer or supplier hears from us.

A food contact statement is a chain of supplier letters. FDA's general rule for indirect food additives, 21 CFR 174.5, lets a substance in a food-contact article rest on one of five bases: generally recognized as safe in food, generally recognized as safe for packaging use, a prior sanction, a listing in parts 175 to 178, or an effective food contact notification. The same rule requires a purity suitable for the use, and says a listing doesn't excuse a package that gives food an off odor or taste. A converter can only stand on what each supplier stated, material by material, so the draft names the basis every supplier claimed and stops where a supplier claimed none.

Coverage turns on the food and the use. 21 CFR 176.170 covers paper and paperboard touching aqueous and fatty foods. Its first table sorts foods into types I to IX, and its second letters the conditions of use from A, heat-sterilized at high temperature, to H, frozen or chilled food reheated in the package. Dry food with no free fat or oil, Type VIII, falls under 176.180 instead. Resin letters often cite 21 CFR 177.1520 for olefin polymers, where one listing may clear some food types under conditions B through H and others only under D through G. So a current letter can still fall short for a hot-filled sauce. The draft sets the brand's food and use beside every letter's stated limits.

Adhesives, inks and notifications have their own catches. Under 21 CFR 175.105, an adhesive needs a functional barrier from the food or must stay within limits, down to the trace at seams and laminate edges for fatty or aqueous food, and its container must read "food-packaging adhesive". NAPIM's 2018 ink guidance is written for non-food-contact printing, and NAPIM defines set-off as substances moving from the printed side to the unprinted side of the next sheet or wrap, so an ink letter about outside print doesn't speak for the inside. FDA's inventory says a food contact notification is effective only for the manufacturer or supplier named in it, and in January 2025 FDA gave notice that the notifications for PFAS grease-proofers on paper and paperboard were no longer effective, the uses having been abandoned. A letter that leans on another company's notification, or on a withdrawn use, goes on the list.

Heavy metal and PFAS letters follow state law. The Toxics in Packaging Clearinghouse model law, drafted in 1989 as the CONEG legislation, bars intentionally added lead, cadmium, mercury and hexavalent chromium in any package or component; its 2021 update adds PFAS and ortho-phthalates, leaving each state to adopt them. Its members are California, Connecticut, Iowa, Maryland, Minnesota, New Hampshire, New Jersey, New York, Rhode Island and Washington. Washington restricts intentionally added PFAS in plant-fiber food packaging in two steps: wraps, plates, food boats and pizza boxes from February 1, 2023, then bags and sleeves, bowls, flat serviceware and open-top and closed containers from May 1, 2024. Maine, outside the Clearinghouse, adopted its own rule in April 2024 for nine plant-fiber types, pinch-bottom bags, portion cups, bakery boxes and deli containers among them, in force from May 25, 2026. The draft matches each state a brand names to the law and the certificate on file. Whether an item meets that law is your signer's call, and none of this is legal advice.

Who signs, and your reviewer. The model law's certificate comes from the manufacturer or supplier, is signed by an authorized official of the company, names any exemption relied on, and is reissued to current buyers after a reformulation. Washington has the certificate kept while the package is in use and three years after its last sale. Maine's phthalates certificate must be signed by a senior manager with authority to speak for the organization. FSC certificates carry their own warning: the certificate alone is no evidence that a product is certified, and a product is covered only when the FSC claim is on the sales and delivery documents, and the certificate code it shows is a different number from the trademark license code. The owner names your reviewer, usually the quality lead who signs today, and they compare each draft and gap list with the statement your team actually sent.

Once your reviewer says yes, each new compliance request gets a sourced draft and a gap list for about 30 days.

The person who signs reads every line, chases the gaps with suppliers, decides and sends. The AI never signs, never judges an item compliant and never writes to a brand or a supplier, and the live month uses the same table.