Chocolate packaging

What a wrapper is protecting chocolate from

Chocolate is dry and mostly fat, and each of those sets a job for the packaging. The jobs differ in how well they have been studied.

• Oxygen, where there are nuts. Dark chocolate with hazelnuts wrapped in aluminium foil in ordinary air kept acceptable quality for about 8 months at 20°C. Behind a laminate with a better oxygen barrier it lasted 11, and with an oxygen absorber in the pack at least 12. (Mexis et al. 2010)
• Moisture. Chocolate that took up enough water to reach a water activity of 0.8 swelled rapidly, and in white chocolate stored for ten months water activity crept up from 0.4 to above 0.5 while oxidation markers rose. (Svanberg et al. 2012; Rossini et al. 2011)
• Mould, which needs that moisture. Dry-tolerant moulds were isolated from commercial bars and grew on chocolate only where it met a moist filling or was held in very humid air. To the naked eye the growth resembled fat bloom. (Kinderlerer 1997)
• Taint from the packaging itself. Tasters detected styrene in milk chocolate flakes held against polystyrene, and in plain chocolate flakes only when the plastic was larger in area or thicker. (Linssen et al. 1991)
• Light, grease, crushing and heat are all given as reasons for chocolate packaging. No study measuring any of them on chocolate was found, and they are listed here without a claim.

Materials, by what was measured

Each material appears with the measurement it has, and no more. Most have one study or none.

• Aluminium foil in air was the ordinary commercial wrap in the hazelnut chocolate study, and the baseline the other packs were compared against. (Mexis et al. 2010)
• Laminated plastic films: polyester on polyethylene did about as well as the foil; the same laminate with a silicon oxide coating, a transparent oxygen barrier, did better; an oxygen absorber did better still whatever the film. (Mexis et al. 2010)
• Plastic films are not equal as barriers to contaminants. Against mineral oil migrating from recycled paperboard over nine months, polyethylene hardly slowed it, oriented polypropylene slowed it strongly and polyester was a tight barrier. (Biedermann et al. 2013)
• Printed polypropylene wrap: plasticisers present only in the ink on the outside reached the confectionery inside, partly by set-off on the reel, where the printed face lies against the food-contact face. (Castle et al. 1989)
• Printed cartonboard: in a British survey, the highest level of the ink component benzophenone found in any food was in a high-fat chocolate product packed in direct contact with the board. (Anderson and Castle 2003)
• Recycled cardboard outer packs and plastic primary packs both contributed hydrocarbons to retail cocoa powders. (Ana et al. (author names as indexed in Europe PMC) 2022)
• Jute sacks, which are packaging too: the oil used to soften jute fibre has been reaching cocoa beans since at least 1991, and was measured doing so again in 2025. (Grob et al. 1991; Moret et al. 2025)
• Paper alone, metallised film, compostable film, trays and boxes: no study of any of them with chocolate was found.

Why a praline needs more than a plain bar

• A filling brings fat that moves. Oil from a peanut filling migrated into chocolate measurably at 30°C and not at 20°C over 17 days, and filled chocolates that stayed free of bloom for eight weeks at 18°C bloomed in the third week at 30°C. Packaging cannot stop this; temperature does. (McCarthy and McCarthy 2008; Ali et al. 2001)
• A filling can bring water. Pralines from nine manufacturers had water activities from 0.70 to nearly 0.90, a range in which yeasts grow, where plain chocolate sits far below it. A pack that traps or admits moisture matters far more here. (Marvig et al. 2014)
• Nuts bring fat that oxidises, which is where an oxygen barrier earned its keep in the one comparison found. Roasted hazelnuts oxidised more readily than raw. (Mexis et al. 2010; Shafiei et al. 2020)
• Hot climates change the question from barrier to survival: a ration chocolate under simulated tropical storage looked unacceptable within seven days whatever it was wrapped in. (Bui and Coad 2014)
• Wafers and biscuits, which must stay dry inside chocolate, and seasonal products with long storage: no study was found.

What the law says about materials that touch food

Described from the texts as read. The two European regulations were read as first published; both have been amended since.

• In the European Union the general rule is one sentence: a material in contact with food must not transfer its constituents in quantities that could endanger health, change the food's composition unacceptably, or spoil its taste or smell. (source 1)
• Plastics have detailed European rules: an overall migration limit of 10 mg per square decimetre of contact surface, summarised by the Commission as 60 mg per kg of food, and specific limits for named substances. (source 2; source 3)
• Paper and board and printing inks do not. They are on the list of materials the Union may regulate, and the Commission's list of materials it has regulated does not include them. Where there is no European measure, each member state may keep its own rules, and the Commission's 2022 evaluation records that those rules differ. (source 1; source 3; source 4)
• In the United States a food-contact substance that counts as a food additive must be authorised, commonly by a notification that the regulator has 120 days to object to and that covers only the named substance and the named supplier. (source 5; source 6)
• The United Kingdom's regulator describes its rules as covering materials expected to touch food or to transfer constituents to it, and gives printing inks and adhesive labels as examples. (source 7)

Migration: what has been found in chocolate and cocoa

• Mineral oil hydrocarbons are the best documented. They reach cocoa from jute sacks, from recycled cardboard and from other sources along the chain. Beans shipped in contaminated jute rose from an average of 0.9 to 9.6 mg/kg of the saturated fraction, about 40% of what entered the whole bean reached the shelled bean, and it carried through into cocoa mass, butter and powder. (Moret et al. 2025; Grob et al. 1993; Ana et al. (author names as indexed in Europe PMC) 2022)
• The European risk assessor separates two fractions. In 2023 it concluded that present dietary exposure to the saturated fraction raises no health concern for any age group, and raised a possible concern about the aromatic fraction, associating genotoxicity and carcinogenicity with compounds of three or more aromatic rings. (source 8)
• That is a change of view: its own account of its 2012 opinion is that the saturated fraction was then described as a potential concern. (source 9)
• In the occurrence data it used, chocolate-coated confectionery had the highest average among chocolate and cocoa products, at about 19 mg/kg of the saturated fraction, from only 13 samples. (source 9)
• The international code of practice for cocoa says bags used to store and move beans need to be free of substances such as mineral oils. (source 10)
• Ink components move too: phthalate plasticisers from wrapper ink rose in a chocolate-coated product from 0.2 to 6.7 mg/kg over 180 days, in a study from 1989. (Castle et al. 1989)

Recyclable, compostable, biodegradable: what the words may mean

Four separate questions hide in the word recyclable: can the material be recycled in principle, is it collected, is there a plant that takes it, and was it in fact recycled. Regulators treat a claim that blurs them as potentially misleading.

• United Kingdom: the competition regulator's guidance says a business must not claim or imply that a product is recyclable if it is not, or if only parts are and the rest prevent recycling; and its example of an unqualified “compostable” claim on an item needing industrial composting is one it calls likely to mislead. (source 11)
• United States: the trade regulator's guides allow an unqualified “recyclable” claim where recycling facilities are available to at least 60% of the consumers or communities where the item is sold. Availability of a facility is the test, not what happens to the item. (source 12)
• The same guides want evidence that a “compostable” item will become usable compost in a safe and timely manner in a composting facility or a home pile, and treat an unqualified “degradable” claim as deceptive if the item will not completely decompose within a year of ordinary disposal. (source 12)
• European Union: the packaging regulation of 2024 requires all packaging to be recyclable, applies from 12 August 2026, and from 2030 admits to the market only packaging graded A, B or C for recyclability, narrowing to A or B from 2038. (source 13)
• The same regulation limits mandatory compostability to a short list of packaging types and requires other packaging, including biodegradable plastics, to be designed for material recycling by 12 February 2028. A recital says the European compostability standard should be revised for composting times, contamination and microplastic release. (source 13)
• What is actually recycled: the European statistics office reports 67.5% of packaging waste by weight recycled in 2023, counting what enters a recycling process and not what is put in a recycling bin, and only two member states met the 55% target for plastic packaging. (source 14)
• In the United States the environment agency estimated that 13.6% of plastic containers and packaging was recycled in 2018, against 80.9% of paper and board packaging, most of that corrugated boxes. For aluminium it had data for drinks cans only, and none for other aluminium packaging, the category that includes foil. (source 15)
• A review of flexible food films found that most multilayer films are not sorted or recycled by the infrastructure that exists. (Bauer et al. 2021)

Less packaging against more waste

• Packaging is not where most of a chocolate's environmental impact lies. In a life cycle assessment of British chocolate, raw materials led every impact category, followed by manufacturing and then packaging; a systematic review of 25 assessments put 77 to 97% of impact in raw materials and manufacture. (Konstantas et al. 2018; Wang and Dong 2024)
• So a wrapper that shortens shelf life can cost more than it saves. A review of recyclable film design warns that restricting material choice could, in the worst case, raise the overall burden through shorter shelf life and heavier packs. That is the authors' assessment and not a measurement. (Bauer et al. 2021)
• A greener material can score worse on one measure and better on another. A biodegradable tray did worse than polypropylene in a life cycle assessment, mainly because it was heavier, and better on an indicator of harm from marine litter. (Boone et al. 2023)
• Transport varies more than packaging does: between about 9 and 51% of an Ecuadorian dark chocolate's carbon footprint, depending on the route to market. (Pérez-Neira et al. 2020)

Sources

Studies are cited by author and year and summarised, with their limits, on the research pages. The official documents are listed here. Each was downloaded and read, and the passage relied on was checked to be in it.

1. European Parliament and Council of the European Union. Regulation (EC) No 1935/2004 of the European Parliament and of the Council on materials and articles intended to come into contact with food (2004-10-27). eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R1935
   Law · EU
2. European Commission. Commission Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food (text as originally published) (2011-01-14). eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R0010
   Law · EU
3. European Commission, Directorate-General for Health and Food Safety. Food Contact Materials: Legislation (web page). food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/legislation_en
   Official guidance, not law · EU
4. European Commission. Commission Staff Working Document: Evaluation of the legislation on food contact materials, Regulation (EC) No 1935/2004, SWD(2022) 163 final (2022-06-09). eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022SC0163
   Official guidance, not law · EU
5. US Food and Drug Administration. Understanding How the FDA Regulates Substances that Come into Contact with Food (web page) (2025-05-08). www.fda.gov/food/food-packaging-other-substances-come-contact-food-information-consumers/understanding-how-fda-regulates-substances-come-contact-food
   Official guidance, not law · US
6. US Food and Drug Administration. About the FCS Review Program (web page) (2022-01-25). www.fda.gov/food/inventory-effective-food-contact-substance-fcs-notifications/about-fcs-review-program
   Official guidance, not law · US
7. Food Standards Agency. Food contact materials regulations (guidance) (2018-04-24). www.gov.uk/government/publications/food-contact-materials-regulations/food-contact-materials-regulations
   Official guidance, not law · UK (England, Wales, Northern Ireland)
8. European Food Safety Authority, Panel on Contaminants in the Food Chain. Update of the risk assessment of mineral oil hydrocarbons in food. EFSA Journal 2023;21(9):e08215 (abstract, as held in PubMed) (2023-09-13). doi.org/10.2903/j.efsa.2023.8215
   Risk assessment · EU
9. European Food Safety Authority, Panel on Contaminants in the Food Chain. Update of the risk assessment of mineral oil hydrocarbons in food. EFSA Journal 2023;21(9):e08215 (full text, from PubMed Central PMC10498375) (2023-09-13). pmc.ncbi.nlm.nih.gov/articles/PMC10498375/
   Risk assessment · EU
10. Codex Alimentarius Commission (FAO/WHO); copy retrieved from the Slovenian government site gov.si. Code of Practice for the Prevention and Reduction of Ochratoxin A Contamination in Cocoa (CAC/RCP 72-2013, now CXC 72-2013) (2013). www.gov.si/assets/organi-v-sestavi/UVHVVR/Varna-hrana/Onesnazevala-v-zivilih/CXP_072e2.pdf
    Voluntary international text · International (Codex)
11. Competition and Markets Authority. Making environmental claims on goods and services (Green Claims Code guidance) (2021-09-20). www.gov.uk/government/publications/green-claims-code-making-environmental-claims/environmental-claims-on-goods-and-services
    Official guidance, not law · UK
12. US Federal Trade Commission. Guides for the Use of Environmental Marketing Claims (Green Guides), 16 CFR Part 260, eCFR text as of 1 January 2025 (2012-10-11). www.ecfr.gov/current/title-16/chapter-I/subchapter-B/part-260
    Official guidance, not law · US
13. European Parliament and Council of the European Union. Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (2024-12-19). eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040
    Law · EU
14. Eurostat. Packaging waste statistics (Statistics Explained; data extracted 10 October 2025) (2025-10-10). ec.europa.eu/eurostat/statistics-explained/index.php?title=Packaging_waste_statistics
    Official statistics · EU
15. US Environmental Protection Agency. Containers and Packaging: Product-Specific Data (web page; data for 2018) (2025-10-23). www.epa.gov/facts-and-figures-about-materials-waste-and-recycling/containers-and-packaging-product-specific
    Official statistics · US

Reviewed 9 October 2026.