Information from ingredient suppliers and documentation about the substances alone do not guarantee safety and regulatory compliance. Examinations demonstrating regulatory compliance are an essential part of the operator’s measures in ensuring food contact material safety and regulatory compliance, and the examinations must be included in the operator’s quality management system. Testing for regulatory compliance requires testing the material’s sensory qualities, and conducting chemical and possibly also microbiological tests.
To ensure chemical safety, the following tests can be performed:
- The total concentration of the substance in the material, mg/kg or mg/dm2 (QM = Quantity in Material)
- The substance’s specific migration based on a specific migration limit (SML). This test specifies the maximum quantity of a specific substance migrated to food, mg/kg
- The overall migration (mg/dm2) (OML) that describes the total amount of all substances that can migrate into food
- According to plastic regulation, the OML is 10 mg/dm2
- The overall migration result reveals nothing about the harmfulness of the migrated substances.
Some tests can be replaced with mathematical calculations if the substance’s residual content in the material is known and if it can be assumed that the entire content would migrate into food.
The test should use an accredited laboratory that is familiar with the examination of food contact materials. Collaboration with a reliable laboratory is essential when assigning tests to food contact materials. A food contact material operator must know the composition of their produced/processed/imported food contact material and the effects of their own process on it, and these matters must be declared to the laboratory to decide on the necessary tests.
The operator must also be familiar with the relevant legislation, potential positive lists of permitted raw materials, and substances with restrictions. If there is no material-specific EU legislation, the operator must specify before the tests what is applied as a basis for safety, or the so called safety references.
To choose the test conditions, it is necessary to know or decide the end use of the material. If necessary, the test conditions and the simulant can be chosen according to a worst case scenario (and this is often the case). In a worst case scenario, the tests are run under the harshest possible test conditions, which means that depending on the results, the widest possible usage context can be found for the product.
The tests must also take into account whether the product is used only once or repeatedly. Products meant for repeated use are tested several times.
Organoleptic testing
The organoleptic testing of the product is based on the requirement of Article 3 of EU Regulation 1935/2004 that the contact material must not adversely affect the organoleptic quality of the food. It is required for all contact materials.
Organleptic evaluations require a trained panel of experts. The operator must ensure that the estimators has sufficient training and expertise if organoleptic tests are performed by the operator.
The tests are usually done as an extended triple test, where the strength of the deviating sample is also evaluated and the quality is described. In the evaluation, an agreed scale is used to evaluate the intensity, and agreed established terms are used to describe the quality. In this way, the results of the testing become comparable with each other.
Questions and answer of testing of food contact materials
Websites of the EU-commissions research laboratory JRC
Guidelines (JRC) of testing conditions (plastic, rubber, silicone and metal)