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Food-contact products: migration testing in plain language

Cups, boards, lunch boxes and kitchen tools touch food, so their materials must not pass harmful substances into it. Here is what that means in practice.

4 min read

In short

  • Migration tests measure what passes from the material into food.
  • The EU uses Regulation (EC) 1935/2004 and specific rules such as (EU) 10/2011 for plastics.
  • The US uses FDA rules in 21 CFR for food-contact substances.
  • Coatings, paints and printed parts are common reasons for failure.

What migration means

Food can absorb tiny amounts of substances from the materials it touches, especially when it is hot, acidic or fatty. Migration tests use food simulants, such as acidic or fatty liquids, at set temperatures and times to measure how much passes across.

The main rules

In the EU, food-contact materials fall under Regulation (EC) 1935/2004, with specific measures for some materials, such as Regulation (EU) No 10/2011 for plastics. In the US, the FDA regulates food-contact substances under Title 21 of the Code of Federal Regulations. Other markets have their own standards, so always confirm the requirement for each country you sell in.

Where products usually fail

The base material is often fine; the decoration is not. Paints, glazes, printed logos, adhesives and coatings are where heavy metals and other substances most often appear.

  • Painted or printed areas that touch food.
  • Ceramic glazes, especially bright colours.
  • Recycled plastics with unknown history.
  • Silicone and rubber parts of lower grade.

Plan it into development

Choose food-grade materials from the start, ask suppliers for material declarations, and test the first production samples. Changing a paint after a failed test is much cheaper than recalling a product from the market.

Different materials, different rules

Plastics, silicone, ceramics, glass, metals, bamboo and paper are each tested in their own way. Ceramics are checked for lead and cadmium release; plastics for overall and specific migration; silicone often for volatile substances. Composite products, such as a bamboo lid with a silicone seal, need each material covered.

Declarations and traceability

In the EU, food contact materials need a declaration of compliance, and the business must keep supporting documents. Ask the factory for material supplier certificates and keep them with your test reports. If an authority or a customer asks, you can show where each material came from.

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