Latest EU food-grade inspection

Food – grade packaging materials in the European Union are mainly tested according to the Regulation (EC) No 1935/20041. The following is a detailed introduction in English:

Relevant Regulations10

• Framework Regulation: Regulation (EC) No 1935/2004 is the general safety requirement, which stipulates that all materials should ensure that they will not contaminate food or endanger human health.
• Specific Material Regulations: For plastics, it is (EU) No 10/2011, which is mainly about migration testing and the list of permitted substances; for regenerated cellulose films, it is Regulation (EC) No 2023/2006; for ceramics, it is 84/500/EEC, which focuses on heavy – metal migration; for active and intelligent materials, it is (EC) No 450/2009. In addition, member states such as Germany (LFGB) and France (DGCCRF) may have additional testing requirements.
• Other Related Regulations: REACH regulation (restriction of SVHC substances of very high concern), heavy – metal limits (such as lead, cadmium, mercury, etc.), and restrictions on chemical substances such as phthalates and primary aromatic amines (PAAs).

Test Items

• Migration Test10:
  • Overall Migration (OM): It simulates the total amount of non – volatile substances released by the material when it comes into contact with food. The test conditions are set according to the actual use temperature and time.
  • Specific Migration (SM): It is used to detect whether the migration amount of specific restricted substances (such as bisphenol A, plasticizers, heavy metals) exceeds the standard. According to (EU) No 10/2011, the test needs to select the simulated liquid (water, alcohol, acidic/oily solution) and temperature (such as 70°C for 2 hours or 40°C for 10 days, etc.).
• Chemical Substance Screening10: Detect restricted substances (such as PAHs, formaldehyde, fluorescent brighteners, etc.), and screen SVHC substances in the REACH regulation (if it exceeds 0.1%, it needs to be notified).
• Common Test Items for Different Materials12: For plastics, it is the overall migration test; for ceramics, it is the lead – cadmium dissolution test; for silicone rubber, it is the overall migration test; for melamine resin, it is the overall migration test and formaldehyde dissolution test; for rubber, it is the overall migration test, nitrosamine content test, and aromatic amine migration test; for paper, it is the pentachlorophenol test, anti – corrosion effect test, and heavy – metal test; for wood, it is the pentachlorophenol test and formaldehyde dissolution test; for metals, alloys, and electroplating, it is the heavy – metal dissolution test.

Test Process10

• Material Classification and Regulation Identification: Determine the material type (plastic, metal, silicone, paper, etc.) and its corresponding EU regulations, and confirm whether the product is for a specific use (such as reusable, high – temperature contact, baby products, etc.), because it may need to meet additional requirements.
• Compliance Testing: Conduct migration tests and chemical substance screening according to the corresponding standards and methods.
• Document Preparation: The manufacturer needs to issue a Declaration of Conformity (DoC), stating that the product complies with EU regulations, and attach a test report. At the same time, prepare technical documents, including material composition, test report, production process, use condition description, etc., as well as supply – chain information (such as the compliance certificate of raw material suppliers).
• Certification and Market Access: Select a laboratory recognized by the EU (such as SGS, TÜV, Eurofins, etc.) for testing. Some materials require a CE mark (such as active and intelligent materials), but most food – contact materials do not have a mandatory CE requirement. In addition, according to the requirements of different member states, relevant certifications may be required, such as LFGB certification in Germany and DGCCRF compliance in France.

Marking Requirements1

Materials and appliances in direct or indirect contact with food should follow the following instructions: mark the words “suitable for contact with food”, or follow the appliance’s instruction manual, or use the symbol specified in Regulation (EC) No 1935/2004.