Is your mithai box food-safe? Choosing materials that can touch sweets

A mithai box has two faces. The outside sells the sweet. The inside touches it.

Most of the attention in a box goes on the outside: the board, the print, the gold foil. The FSSAI rules care about the inside. Anything that touches your sweets, or is likely to, must be food grade. It must not add anything to the food, not even a smell.

In practice, that means food-grade board or a food-grade liner on the inside, no print and no recycled grey board against the sweets, trays and films that meet their Indian Standard, and a lab certificate that you, the shop, keep on file.

We make plastic films and paper packaging at Jagannath Polymers in Jaipur, and we export to 20+ countries. I know board and film far better than I know khoya. So this guide stays on the packaging side, and your food-safety consultant should confirm what applies to your product.

What does the law actually say?

The rule is the Food Safety and Standards (Packaging) Regulations, 2018. It was notified on 24 December 2018, and every food business had to comply by 1 July 2019. It has been amended three times since, on 25 January 2022, 30 August 2022 and 28 March 2025. We read the consolidated text on the FSSAI website, Version V, dated 2 April 2025.

In our view, two lines in it matter most for a sweet shop.

Regulation 3(2) says any material that touches food, or is likely to, and is used for packing, preparing, storing, wrapping, transporting, selling or serving it, must be of food grade quality. That covers the box, the tray, the butter paper, the counter tray and the paper you hand a samosa in.

Regulation 2(1)(b) defines food grade. The material must be safe and suitable for its use, must not endanger health, and must not change the composition of the food or its taste, smell and feel.

Read the last part again. A box that leaves an ink smell in your kaju katli fails the definition, even if nobody falls ill.

We think it is also the line that is easiest to miss.

FSSAI has also published a draft amendment dated 26 February 2026 that adds new definitions, including one for "food contact material". Ask your consultant whether it has been finalised.

Can the printed side touch the sweets?

No. Regulation 3(10) says the printed surface of packaging must not come into direct contact with food. Regulation 3(9) says printing inks on food packages must meet IS 15495.

For a mithai box, we would rule out three habits:

1. A printed lid that presses on the top layer of barfi.
2. A doily or butter paper printed with your logo, placed print side up under the sweets.
3. Printed paper cups, unless the print is only on the outside of the cup.

Ask your box maker for a written declaration that the inks meet IS 15495. Then keep the print on the outside.

Newspaper and "any such material"

Regulation 3(11) is short. Newspaper or any such material shall not be used for storing and wrapping food.

This one matters most at the namkeen and kachori counter, where newspaper has long been used to soak up oil. In my reading, printed waste paper of any kind counts as "such material". Use plain food-grade paper.

What should the box itself be made of?

Regulation 4(1) sets the rules for paper and board. The board must be of uniform formation and thickness, and free from specks, grease marks, cuts and pinholes. Paper used for boxes, cartons, plates, cups and lids that touch food must be food grade and free from contaminants.

Schedule I then lists the Indian Standards for paper and board that touch food. We have put them in one table:

A note under that schedule says any wax used to coat paper or board must be paraffin wax of Type I under IS 4654. The wax is easy to forget. We would give it one line on your order.

Why I would keep recycled board away from sweets

Many mithai boxes are made of duplex board, which has a white printed face and a grey back. The grey back is usually recycled fibre.

Recycled fibre carries whatever was printed on the old paper. Germany's Federal Institute for Risk Assessment (BfR) explains in its questions and answers on mineral oil in food (updated 31 July 2023) that most conventional newspaper inks contain mineral oils, that recycling does not fully remove them, and that they can pass from recycled cardboard into food. It names three fixes: virgin fibre board, mineral oil-free inks, or a functional barrier in the pack.

The BfR work focuses on dry foods with a large surface area, such as rice and flour. Mithai is a different case, but I would not take the chance with a ghee-rich sweet sitting on grey board for a week. Our advice is to let only virgin food-grade board, or a proper barrier layer, touch the sweets.

A sheet of butter paper gives you a clean surface. It is not automatically a barrier against what is inside recycled board. If you need a barrier, ask for a film or foil laminate. Then ask your supplier which one you are getting, in writing.

I would not accept a verbal answer on this.

Butter paper, glassine and foil

"Butter paper" is a shop name, not a standard. When you buy it, ask which of the papers in the table above it actually is, greaseproof paper (IS 6622) or vegetable parchment (IS 7161), and ask for the test report.

Bare aluminium foil for food packaging has its own standard, IS 15392.

The shiny boards need a closer look.

On silver and gold boards, the shine usually comes from a metallised film or foil laminated onto the board. If that face is on the inside, it is a food-contact layer, and the questions in the next section apply to it.

Plastic trays, cups and inserts

Many mithai boxes now have a thermoformed tray inside. These are usually PET, PP or polystyrene. Schedule III lists the Indian Standard for each plastic that touches food. For example, PET is IS 12252, PP is IS 10910, polystyrene is IS 10142 and polyethylene is IS 10146.

Every plastic food-contact material must also pass two tests under regulation 4(4):

1. Overall migration of not more than 60 mg/kg, or 10 mg/dm², tested as per IS 9845, with no visible colour migration.
2. Specific migration limits for a list of substances, including antimony and DEHP, which were added in 2022.

Coloured trays, the gold and maroon ones that look so good in a Diwali box, need one more thing. The pigments in plastics that touch food must meet IS 9833. Ask for it in writing. I would never choose a tray on its colour alone.

Recycled plastic needs extra care. The March 2025 amendment allows recycled PET for food only under standards FSSAI notifies, and FSSAI issued its guidelines for recycled PET in the Gazette on 23 May 2025. The recycler must be authorised by FSSAI. Plain mechanical recycling without a step that removes contaminants is not allowed for food contact. A tray sold as "recycled" without that authorisation should not hold your sweets. Recycled PP and polystyrene have no such route at all.

One more practical point from us. Regulation 3(3) says packaging must suit the product and the conditions it meets. If jalebi, halwa or gulab jamun go into a tray while still hot, ask the supplier for the tray's temperature limit before you do it.

The film wrapped around the box

This one is not an FSSAI rule. It comes from the Plastic Waste Management (Amendment) Rules, 2021, notified on 12 August 2021.

From 1 July 2022, those rules banned the manufacture, sale and use of "wrapping or packing films around sweet boxes", along with plastic plates, cups, cutlery and decorative thermocol. The Central Pollution Control Board press release of June 2022 repeats the full list. Film made of compostable plastic is exempt from that part of the ban.

The same list also names plastic "trays", in the line with plates and cutlery. If you use plastic trays inside your boxes, ask your state pollution control board or your environmental consultant how they read that word for your pack. I would rather you ask than guess.

Who must hold the test certificate?

You do.

Regulation 3(14) says every food business operator must obtain a certificate of conformity from a NABL-accredited laboratory for the packaging material that touches food. The box maker usually arranges the test, but the legal duty sits with the sweet shop or bakery.

Keep each report in a file with the purchase order it belongs to. Check that it names the material, the standard, the date and the lab, and that the lab's NABL accreditation covers that test.

What to ask your box supplier

Put these on your next order. Ask the same of every supplier, us included, because we would expect our own customers to ask them:

1. The board grade, the Indian Standard it meets, and whether the inner face is virgin fibre.
2. The material and standard of anything else that touches the sweets: liner, tray, cup or foil.
3. A declaration that the inks meet IS 15495, and that print is on the outside only.
4. An overall migration report under IS 9845 for every plastic tray or film, and IS 9833 for coloured trays.
5. The NABL lab certificate for each food-contact layer.
6. No recycled material in any food-contact layer, unless it is FSSAI-authorised recycled PET.
7. The highest temperature the tray can take, if anything goes in hot.
8. A batch number on every carton of boxes, so a problem can be traced.

If a supplier cannot show you a test report for the layer that touches your sweets, keep looking.

Two checks you can do in your own shop

1. The smell check. Open a fresh bundle of boxes, put your nose right inside one and breathe in. Do the same with a tray. A sharp smell of ink, glue or solvent means the pack is not ready for food. Fat-rich sweets pick up smells easily, and you will hear about it from customers before any lab tells you.
2. The overnight ghee check. Put a piece of your most ghee-rich sweet on the inside of an empty box or on its liner, close the lid and leave it overnight. Next morning, look at the board under it and on the outside. A dark grease patch means the liner is not holding the fat. Then wipe the inside surface with a white tissue dipped in a little cooking oil. Any colour on the tissue means colour can move into food.

Neither check replaces a lab report. I still like both, because they can catch a bad lot before your customers do.

Next, get the outside of the box right. Our guide to FSSAI labelling for sweet shops covers what must be printed on it.

Pull out last month's box invoice today. If it only says "food grade", send your supplier these eight questions.