thanks Charles for your comments ,
I under stand that the food contact is excluded ( as below in red ) , I'm right ! , this part is from Q& A in the 'Guidance for Industry: Questions and Answers Regarding Food Facility Registration (Sixth Edition) ' in the FDA website ( the link is below ) update November ,2014 ,Packaging is not to be registered excluding food contact ,
16.10 Q: Are facilities that manufacture food packaging required to be registered as food facilities?
A: No. The definition of "food" in 21 CFR 1.227(b)(4)(i)(A), for the purposes of food facility registration, excludes food contact substances as defined in section 409(h)(6) of the FD&C Act (21 U.S.C. 348(h)(6)). Consequently, a facility that manufactures/processes, packs, or holds food contact substances, i.e., food packaging, is not required to be registered.
However , after reading this several times , It is not clear , even by exploring in the food contact surface it is not directly related to packaging .
I think you are more to the right direction , as I do not have a sharp evidence except my interpretation for the red statement.
Best regards ,