Food Contact Material Testing: Safeguarding Health and Compliance


In the diverse world of manufacturing and materials science, ensuring the safety of materials that come into contact with food is a critical concern. Quality management professionals, especially those in the plastic recycling industry, must navigate the complex landscape of regulations and testing requirements to ensure their products are safe for consumer use. This blog post introduces the concept of Food Contact Material (FCM) testing, its importance, common materials tested, and the regulatory framework in Europe, focusing on the recent developments in EU regulations.

What is Food Contact Material Testing?

Food Contact Material Testing refers to the evaluation of materials and articles intended to come into contact with food to ensure they are safe and do not transfer their constituents into food in quantities that could endanger human health. This type of testing is crucial as it helps in assessing the purity and safety of materials like plastics, paper, coatings, metals, and glass that are used in food packaging, processing machinery, or utensils.

Why is Food Contact Material Testing Important?

Testing is vital for several reasons:

  • Health Safety: It prevents harmful contaminants from leaching into food.
  • Regulatory Compliance: Ensures that products meet strict safety standards set by regulatory bodies.
  • Consumer Confidence: Helps in building trust with consumers regarding the safety of the products they use.

Common Materials to be Tested

The most frequently tested materials include:

  • Plastics: Especially recycled plastics, which might contain residues from their previous uses.
  • Metals and Alloys: Particularly those used in utensils and containers.
  • Paper and Cardboard: Often used in packaging and can contain harmful dyes or adhesives.
  • Glass and Ceramics: Typically tested for leachable lead and cadmium.
  • Coatings: Which are critical in cans and other containers to prevent metal leaching into food.

Regulatory Framework in Europe

The European Union has a robust regulatory framework for materials that come into contact with food. This framework has evolved over time to address emerging scientific knowledge and technological advances in material manufacturing.

Historically, the EU's approach has been characterized by both specific measures for certain materials and a broad, overarching regulation (EC) No 1935/2004, which stipulates that materials must not release their constituents into food at levels harmful to health. In recent years, updates and new regulations have been introduced to address specific concerns, particularly around recycled materials and the presence of non-intentionally added substances (NIAS).

EU 2022/1616 and Article 32 on Functional Barrier

One of the significant updates in EU regulations is EU 2022/1616, which specifically addresses recycled plastic materials in food contact applications. The regulation sets out stricter requirements to ensure that recycling processes are robust and safe.

A key component of this regulation is Article 32, which discusses the concept of a 'functional barrier.' This is a layer within the recycled material that is effective enough to prevent contaminants from migrating from the recycled layer to the food. Ensuring the presence and efficacy of such barriers is crucial for the safety of recycled plastic food contact materials.

Non-intentionally Added Substances (NIAS)

NIAS are chemicals that are not deliberately added to materials but can form during manufacturing or recycling processes. Identifying and quantifying these substances is challenging yet essential for safety assessments. The most common analytical methods for NIAS screening include:

  • Gas Chromatography-Mass Spectrometry (GC-MS): Ideal for volatile and semi-volatile compounds.
  • Liquid Chromatography-Mass Spectrometry (LC-MS): Used for non-volatile compounds.
  • High-Performance Liquid Chromatography (HPLC): Often used alongside photodiode array or mass spectrometric detection for a broad range of potential contaminants.

Migration Testing

Migration testing is a key part of FCM safety assessments, designed to simulate the conditions under which materials come into contact with food and measure the migration of substances.

  • Overall Migration Testing: Measures the total amount of non-volatile substances that migrate from the material to a food simulant (a chemical mixture that mimics food). This test ensures that the quantity of migrated substances is within safe limits.
  • Specific Migration Testing: Focuses on specific harmful substances (like lead, cadmium, or bisphenol A) that could migrate from the material into the food. This testing is essential for proving compliance with specific legal limits.


Food Contact Material Testing remains a dynamic field influenced by technological advancements and regulatory changes. For quality management professionals in the plastic recycling industry, staying informed about these changes is crucial for ensuring compliance and protecting consumer health. At KÖR, we provide a comprehensive marketplace for testing services that helps manufacturers navigate these complex requirements efficiently and effectively. Whether it's ensuring the efficacy of functional barriers or accurately measuring migration levels, our platform supports you in achieving compliance and maintaining the highest safety standards. Lear more about our NIAS testing services today!