Migration Testing in Food Packaging: Ensuring Safety of Food Contact Materials

Migration testing is the scientific evaluation of the transfer of chemical substances from food contact materials (FCMs) such as plastics, laminates, films, and containers into the food or beverage they come in contact with.

These materials, though designed to be inert, can release substances such as:

• Residual monomers
• Plasticizers
• Additives
• Stabilizers
• Ink or adhesives

Migration testing ensures that such substances do not leach into food at harmful levels, thereby protecting consumer health and ensuring regulatory compliance.

Why Does Migration Happen?

Migration occurs due to chemical interactions between packaging material and food, especially under:

• High temperatures (e.g., hot filling, microwaving, sterilization)
• Prolonged storage (e.g., shelf-stable items)
• Fatty, acidic, or alcoholic food matrices (which promote leaching)

Key Factors Influencing Migration

Types of Migration

Overall Migration (OM)

• Measures the total quantity of non-volatile substances that migrate into food or food simulants.
• Expressed as:
  • mg/kg of food or
  • mg/dm² of contact surface

Specific Migration (SM)

• Measures the migration of particular substances, which may be toxic or regulated.
• Examples:
  • Phthalates (plasticizers)
  • BPA (bisphenol A)
  • Styrene (monomer in polystyrene)
  • Heavy metals (e.g., lead, cadmium)

Migration testing is essential to ensure that such materials do not release hazardous or undesirable substances into food that could affect safety, nutrition, or sensory properties.

To meet safety standards, all FCMs must be:

• Chemically stable under intended use conditions
• Non-toxic and free from harmful contaminants
• Compliant with regulatory migration limits (e.g., IS 9835, FSSAI, EU 10/2011)
• Suitable for the specific food type they will contact (e.g., acidic, fatty, alcoholic foods)

Common Types of FCMs and Migration Testing Considerations

Why Migration Testing is Critical for FCMs

• Regulatory Compliance: Ensures packaging materials meet Indian and global migration standards.
• Health & Safety Assurance: Prevents exposure to potentially harmful substances leaching into food.
• Packaging Approval: Supports the validation of new packaging types including eco-friendly and recycled materials.
• Trade & Export Readiness: Required for certifications and global market acceptance.
• Brand Protection: Minimizes risk of recalls and enhances consumer confidence.

Health Concerns Related to Migration

Migration of unsafe substances from packaging into food can lead to:

• Hormonal disruption
• Reproductive and developmental issues
• Toxic effects on the liver, kidneys, or nervous system
• Carcinogenic potential in some substances
• Allergic or chemical sensitivity reactions

Consumers are unknowingly exposed to these substances, making migration testing a critical step in public health protection.

Regulations and standards

FSSAI defines a "specific migration limit" as the maximum permitted amount of a given substance released from a material or article into food or food simulants. All plastic materials and articles intended to come into contact with food must not release substances in quantities exceeding the SMLs listed in the relevant tables of the regulations.

General Requirements:

• All packaging materials in direct or indirect contact with food must be of food-grade quality.
• Packaging materials must be suitable for the type of product, storage, and transportation conditions.
• Materials must withstand mechanical, chemical, or thermal stresses during normal use.
• Food products must be packed in clean, hygienic, and tamper-proof containers.
• Printing inks must conform to IS: 15495, and the printed surface must not directly contact food.

https://www.fssai.gov.in/upload/uploadfiles/files/Compendium_Packaging_V_%2002-04-2025.pdf

Plastic-Specific Regulations:

• Plastic containers and articles must comply with migration limits for various substances, including newly specified limits for antimony (0.04 mg/kg) and DEHP (1.5 mg/kg).
• Only plastics processed through FSSAI-approved recycling technologies are permitted in food packaging, and recycled plastics must meet strict migration limits to prevent contamination.
• Recycled PET (rPET) is allowed as a food contact material only if it passes stringent decontamination and testing protocols, with compliance to IS: 12252, IS: 9845, and IS: 9833, and must be tested in NABL/ILAC accredited labs.

Paper-Based FCMs:

• All paper-based food contact materials must be produced using virgin pulp, free from optical brightening agents, and must comply with migration limits for both direct and indirect contact.

Traceability and Labeling:

Packaging must clearly indicate the use of recycled materials and ensure product traceability, with specific marking and labeling requirements for recycled PET.

2025 Amendments:

The latest FSSAI Packaging Regulations (effective April 2025) emphasize the use of recycled plastics, provided they meet SMLs and are processed through approved methods. These changes aim to balance food safety with environmental sustainability.

https://www.fssai.gov.in/upload/uploadfiles/files/Compendium_Packaging_V_%2002-04-2025.pdf

Recycled PET Guidelines (May 2025):

New guidelines detail the acceptance criteria for using recycled PET in food contact materials, focusing on safety, process validation, and labeling for transparency.

https://www.indialaw.in/blog/civil/fssai-recycle-pet-food-contact-material/

Migration testing standards and regulations play a crucial role in ensuring the safety and compliance of food contact materials (FCMs). Here are some key standards and regulations related to migration testing:

European Union (EU) Regulations

• European Framework Regulation (EC) No. 1935/2004: This regulation establishes general requirements for FCMs, including migration limits and safety criteria.
• European Plastic Regulation (EU) No. 10/2011: This regulation specifically addresses plastic FCMs, setting overall migration limits and specific migration limits for various substances.

https://food.ec.europa.eu/safety/chemical-safety/food-contact-materials/legislation_en

What Should Be Tested?

Migration testing typically focuses on:

• The total migration load (overall migration)
• The presence of specific substances such as residual monomers, plasticizers, heavy metals, and solvents
• The interaction between food simulants and packaging under different temperature and storage conditions
• Material performance and stability over time

These parameters are tested using laboratory-controlled food simulants that replicate different food types (aqueous, acidic, fatty, alcoholic).

How Is Migration Testing Performed?

1. Selection of Food Simulants – Simulants like water, acetic acid, ethanol, and iso-octane are chosen based on the type of food the packaging will contact.
2. Exposure Conditions – Packaging samples are exposed to simulants at specified temperatures and durations to mimic real-world use.
3. Analytical Testing – Advanced techniques such as GC-MS, HPLC, ICP-MS, and FTIR are used to detect and quantify migrated substances.
4. Result Interpretation – The data is assessed to determine whether the packaging complies with safety standards and regulatory expectations.

Role of IS 9835 in Migration Testing

IS 9835 is the Indian Standard that outlines the methodology, conditions, and material safety requirements for plastic materials used in contact with food. It defines the use of food simulants, sets migration limits, and mandates performance checks for packaging materials under simulated usage conditions.

This standard is enforced under the FSSAI Packaging Regulations and ensures food safety from a packaging perspective.

Eurofins' Role in Migration Testing of Food Contact Materials (FCMs)

Eurofins offers comprehensive migration testing services for a wide range of food contact materials, helping food businesses, packaging manufacturers, and exporters meet Indian and global regulatory requirements.

Scope of Migration Testing at Eurofins

• Overall Migration: To measure total non-volatile chemical transfer from packaging into food simulants.
• Specific Migration: To detect and quantify individual hazardous substances like:
  • Plasticizers (e.g., DEHP)
  • Residual monomers (e.g., styrene)
  • Heavy metals (e.g., lead, cadmium)
  • Additives and stabilizers
• Packaging Validation: For new, recycled, or biodegradable packaging materials.

Technologies & Capabilities

Eurofins uses advanced instrumentation and validated methods for accurate, reliable results:

Testing as per Regulatory Standards

Eurofins conducts migration testing as per:

• IS 9835 – Indian Standard for migration testing.
• FSSAI Packaging Regulations – Mandatory for Indian market
• EU Regulation (EU) No. 10/2011 – For exports to Europe
• US FDA 21 CFR – For North American markets
• Codex Guidelines – For global harmonization

 Materials Tested at Eurofins

Eurofins provides testing support for a wide variety of FCMs:

• Plastics (PET, PE, PP, PS, PVC, etc.)
• Multi-layer packaging (films, pouches, laminates)
• Recycled plastic packaging (especially rPET)
• Coated paperboards and printed cartons
• Glass, ceramics, and metal containers with coatings
• Composite and biodegradable materials

Eurofins & Recycled Packaging Compliance

With growing focus on sustainability and circular economy, Eurofins plays a vital role in validating recycled materials like:

• Recycled PET (rPET) for bottles and containers
• Post-consumer recycled (PCR) plastics.
• Migration testing after decontamination validation.
• Supporting clients in compliance with traceability, labeling, and regulatory submissions

 Why Choose Eurofins for Migration Testing?

Contact Us