Any material intended to come into contact with food must undergo migration testing to verify that its composition poses no risk to consumer health. However, many substances present in packaging (plastics, papers, glues, varnishes, or inks) can migrate into food during storage or heating. To prevent these risks, migration testing has become a cornerstone of laboratory analysis, bridging regulatory requirements and food safety imperatives.
This article provides an in-depth look at the objectives, methods and regulatory framework of migration testing, highlighting the solutions offered by YesWeLab to ensure the conformity of packaging materials.
Table of Contents
Why perform migration tests?
Protecting consumer health
Packaging materials, although external to food, are never completely inert. Over time, certain substances can be released from these materials and migrate into the food, potentially altering its chemical composition. These transfers are often imperceptible to the naked eye or taste, but can pose a real risk to human health.
Substances that can migrate include:
- Residual monomers , resulting from the manufacture of plastics (e.g., styrene, acrylonitrile),
- Plasticizers are used to make materials more flexible.
- Heavy metals , present in inks or glues,
- Aromatic amines or nitrosamines , derived from certain dyes or elastomers.
The migration of these compounds can lead to long-term toxic effects, such as endocrine disruption, liver disorders, and even carcinogenic risks. Therefore, migration testing is essential to ensure that transfer levels remain well below the thresholds permitted by law.
Meeting strict regulatory requirements
In Europe, materials intended to come into contact with food must comply with a particularly stringent regulatory framework. Regulation (EC) No 1935/2004 forms the basis of this legislation. It requires that all materials intended to come into contact with food:
- Does not release substances in quantities likely to harm human health.
- It does not alter the composition of food.
- Does not deteriorate their organoleptic properties (taste, smell, texture).
This regulation is supplemented by Regulation (EU) No 10/2011 , which applies specifically to plastic materials . It defines overall migration limits (≤ 10 mg/dm² of material) and specific migration limits for more than 900 substances.
In parallel, testing standards such as EN 1186 describe the experimental conditions to be met for measuring migration. Tests must be carried out by laboratories accredited according to ISO 17025 , which guarantees the reliability and reproducibility of the results.
At the international level, the FDA (Food and Drug Administration) also sets requirements for materials marketed in the United States. Exporting manufacturers must therefore anticipate migration tests tailored to each target market.
Securing market entry and avoiding recalls
Non-compliant packaging can have serious consequences: batch withdrawals, product recalls, administrative penalties, loss of consumer confidence, and even damage to brand reputation. In some cases, companies must revise their formulation, modify the packaging material, or change suppliers, which generates significant costs.
Performing migration tests beforehand allows you to:
- To validate compliance before a new product is marketed,
- To reduce the risk of non-compliance by anticipating interactions between packaging and food products,
- To ensure complete traceability of analyses, essential in the event of control or regulatory audit.
To adopt a quality and CSR approach
Beyond regulatory requirements, migration testing contributes to a comprehensive approach to quality and corporate social responsibility (CSR). It helps guarantee consumers safe, healthy packaging that meets environmental expectations. Some companies choose to go beyond minimum requirements by systematically integrating migration controls into their packaging validation protocols.
In this context, YesWeLab supports manufacturers in all sectors — agri-food, cosmetics, nutraceuticals — in the rigorous management of the compliance of their packaging through a digital platform and a network of more than 200 partner laboratories.
The different types of migration analyzed in the laboratory
When a material comes into contact with food, it can release one or more substances into that food. To assess this phenomenon, laboratories distinguish between several types of migration , each measuring different aspects. These analyses are complementary and allow for a precise evaluation of the material's behavior under conditions simulating real-world use.
Global migration: assessing the material's inertia
Overall migration measures the total amount of substances that migrate from a material into a food, without distinguishing the chemical nature of these substances. It is expressed in mg of material released per kg of food (mg/kg) or per dm² of contact surface (mg/dm²) .
The aim of this analysis is to verify the chemical inertness of the material , that is, its ability to remain non-reactive with food. The lower the value, the more stable and suitable the material is considered to be for food use.
According to Regulation (EU) No 10/2011 , the overall permitted migration limit is set at 10 mg/dm² for plastic materials.
Example :
A plastic film intended for cheese packaging is subjected to an overall migration test. The laboratory uses a fat simulant (vegetable oil) to reproduce real-world usage conditions. The test reveals a total migration of 7.2 mg/dm², which is below the regulatory limit : the material is therefore considered compliant for this use.
This method is particularly useful in the development phase of new packaging , to compare the inertness of several formulations, or to validate recycled materials.
Specific migration: targeting risky substances
Unlike overall migration, specific migration aims to measure the amount of a given substance that migrates into food. This approach is necessary to control regulated substances whose presence above a certain threshold could pose a risk to consumers.
Among the substances frequently analyzed:
- Bisphenol A (BPA) : an endocrine disruptor banned in certain uses (baby bottles, thermal tickets),
- Phthalates : plasticizers suspected of having reprotoxic effects,
- Aromatic amines : derived from certain colorings or additives,
- Styrene, acrylonitrile : monomers of plastic resins,
- Formaldehyde : a volatile compound found in some glues or papers.
Each substance is associated with a specific migration limit (SML) defined in the annexes to Regulation (EU) 10/2011. For example, the SML for formaldehyde is set at 15 mg/kg of food .
Analytical techniques:
To detect and quantify these substances, laboratories use sensitive and selective methods, such as:
- HPLC (high-performance liquid chromatography),
- GC-MS (gas chromatography with mass spectrometry),
- ICP-OES (Plasma Spectrometry for Metals).
These tests are carried out after a contact step between the material and a food simulant (water, acid, oil, etc.) for a defined time and at a defined temperature. The results obtained are then compared to regulatory limits.
Emerging substances under surveillance: focus on PFAS
PFAS polyfluoroalkyl substances) form a family of over 4,700 synthetic compounds used for their non-stick, waterproof, and heat-resistant properties. They are found in particular in:
- Grease-resistant packaging (paper, cardboard, trays),
- Cooking surfaces (films, pans, griddles),
- Some technical textiles or composite materials.
These substances are now in the sights of health authorities because of their persistence in the environment and their potentially harmful effects on health: hormonal, immune, metabolic disorders.
To date, not all PFAS are subject to specific migration limits (except in certain cases, such as for paper and cardboard). However, Regulation (EC) No 1935/2004 , in Article 3, stipulates that any transfer of substances must not pose a risk to human health . Consequently, a growing number of manufacturers are anticipating this development by requesting targeted PFAS analyses in their packaging materials.
A complementary approach for enhanced security
Overall and specific migration tests are complementary . A material may exhibit low overall migration but release a hazardous substance in quantities exceeding regulatory limits. Conversely, higher overall migration may indicate the presence of harmless compounds.
For this reason, it is recommended to combine the two types of analysis , particularly in the following cases:
- New packaging or change in formulation,
- Reuse of recycled or multi-layered materials,
- Exporting to several geographical areas with different regulations.
The analytical approach chosen will also depend on the results of a document analysis (supplier technical data sheet, declaration of conformity, etc.) and a risk analysis based on the intended use of the material.
YesWeLab offers a comprehensive assessment of material migration through a combined range of general and specific analyses , in compliance with European and international regulations. Thanks to its network of specialized laboratories, manufacturers benefit from tailored scientific and regulatory support.
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Methodology for laboratory migration tests
Migration tests follow a standardized and rigorous methodology to guarantee the reliability of the results. Each step of the process is governed by precise standards to best simulate the real-world conditions of use of materials in contact with food. This methodology is based on the choice of the simulant, the definition of experimental conditions (time, temperature, contact surface area), and the analysis of the extracted substances.
The choice of food simulants
Food simulants are standardized liquid substances used to replicate the behavior of different types of food during migration tests. They allow for the evaluation of a material's ability to release chemical substances when in contact with a given food product.
The choice of simulant depends on the physicochemical nature of the target food: aqueous, acidic, fatty, alcoholic, or mixed. Here are the main simulants defined by Regulation (EU) No 10/2011:
| Simulant | Type of food represented |
| Distilled water | Watery foods (fruits, vegetables, drinks) |
| Acetic acid 3% | Acidic foods (fruit juice, sauces, vinegar) |
| Ethanol 10% | Hydrophilic or slightly alcoholic aqueous foods |
| Ethanol 20 to 50% | Alcoholic or fatty foods (creams, sauces) |
| Vegetable oil or iso-octane | Fatty foods (cured meats, cheeses, prepared meals) |
Choosing the right simulant is crucial, as a poor match can lead to underestimation or overestimation of migrations . In some complex cases (combined or processed foods), a comparative approach can be used with several successive simulants.
Definition of contact conditions: temperature, duration, surface area
The contact conditions during testing are established to material usage scenarios Directive 82/711/EEC , which establishes tables of correspondence between types of use and experimental conditions.
Among the essential parameters:
- Contact temperature : variable depending on the use of the material (refrigeration, ambient temperature, cooking). It can range from 5°C to 121°C.
- Contact time : from a few minutes to several days (up to 10 days for materials intended for long-term storage).
- Contact surface : the quantity of material tested is expressed in dm², and compared to a volume or mass of standard food.
Example :
A plastic film intended for packaging microwaved ready meals is tested at 70 °C for 2 hours, with a surface area/volume ratio of 1 dm²/100 mL of simulant.
These conditions are strictly regulated , as they strongly influence the material's behavior. Excessive temperature or duration can artificially amplify migration, while an underestimated test does not guarantee the material's actual safety.
Sample preparation and analysis protocol
Once the parameters are defined, the laboratory prepares the samples to respect the standardized contact surface area (generally 1 dm²). The material is immersed or brought into contact with the chosen simulant, in an inert (glass, PTFE), airtight container, placed in a temperature-controlled environment.
After the contact phase, the simulant is analyzed according to the nature of the expected substances :
- Overall analysis : evaporation of the simulant and weighing of the dry residues (overall migration),
- Specific assay : extraction and analysis by chromatography (HPLC, GC-MS), spectrophotometry, or ICP spectrometry.
Each analysis is performed with calibration standards, analytical blanks, and replicates to ensure reproducibility and accuracy of results.
The laboratory then prepares a analysis report , stating:
- The substances detected,
- The measured quantities,
- Compliance with migration limits,
- The standards used for testing.
Reliability of results: ISO standards and accreditations
To guarantee the reliability and validity of the results obtained, migration tests must be carried out according to the requirements of ISO 17025 , which defines the competence criteria for testing and calibration laboratories. In France, this standard is complemented by COFRAC , which attests to the conformity of the methods used and the rigor of the laboratory's quality system.
The ISO 17025 standard notably requires:
- Complete traceability of samples and results,
- Validated testing methods according to best practices,
- Regular internal and external quality controls,
- Strict document management and periodic audits.
The results issued by an accredited laboratory are legally binding and recognized by health authorities and certification bodies, which constitutes a guarantee of reliability for manufacturers.
YesWeLab works exclusively with ISO 17025 and/or COFRAC accredited laboratories, selected for their sector expertise. Thanks to its digital interface, YesWeLab facilitates traceability, secure retrieval of results, and regulatory compliance of technical files, essential in the event of a quality audit or official inspection.
Analytical techniques used for migration testing
Migration tests rely on a combination of standardized protocols and cutting-edge analytical techniques. Their objective is to precisely measure the substances released by food contact materials, whether it be overall or specific migration. To achieve this, laboratories use sophisticated physicochemical methods capable of detecting minute traces of compounds in complex matrices. This scientific rigor ensures the reliability of the results and demonstrates the materials' compliance with regulatory requirements.
High-performance liquid chromatography (HPLC)
chromatography (HPLC) is one of the most widely used laboratory methods for analyzing specific migrations. It allows for the separation, identification, and quantification of chemical compounds present in very low concentrations in a liquid (food simulant, packaging extract, etc.).
Principle:
The analyzed mixture is injected into a chromatographic column filled with a stationary phase. The different molecules interact to varying degrees with this phase, causing their separation during elution. A detector (usually UV or fluorimetric) then measures their concentration.
Benefits :
- Very high precision and sensitivity ,
- Suitable for a wide range of substances (phthalates, bisphenol A, amines…),
- Compatible with complex matrices, such as fatty or alcoholic simulants.
Example of application:
The analysis of formaldehyde or aromatic amines in plastic packaging or printed coatings is commonly carried out by HPLC, particularly in the food and cosmetics sectors.
Gas chromatography coupled with mass spectrometry (GC-MS)
Gas chromatography allows the analysis of volatile or semi-volatile compounds, such as residual solvents, aromatic hydrocarbons, or non-reactive monomers. When coupled with mass spectrometry (GC-MS) , it offers extremely precise identification of molecules.
Principle:
After extraction, the sample is vaporized and then injected into a heated column. The substances are separated according to their volatility. At the outlet, a mass spectrometer identifies them according to their unique molecular signature.
Benefits :
- Very high specificity and sensitivity
- This allows for confirmation of the exact identity of the migrating substances.
- Recommended for demanding regulatory analyses , particularly in the case of CMR substances (carcinogenic, mutagenic, reprotoxic).
Example of application:
The determination of styrene , vinyl chloride , or odorous substances from printing or gluing is often entrusted to GC-MS.
Inductively coupled plasma optical emission spectrometry (ICP-OES)
ICP-OES spectrometry is used to quantify metallic elements present in materials, particularly heavy metals (lead, cadmium, mercury, arsenic, nickel, chromium). These elements can originate from pigments, stabilizing additives, or inks.
Principle:
The sample is mineralized and introduced into a very high temperature plasma (approximately 10,000 K). The atoms emit a characteristic light which is analyzed by optical spectrometry.
Benefits :
- Simultaneous multi-element detection,
- Very low detection limit (trace level),
- Suitable for the specific migration of metals in ceramic, metallic or plastic materials.
Example of application:
In glass and enamel-based materials, the detection of lead and cadmium is mandatory according to Directive 84/500/EEC. These analyses are also essential for decorated objects (printed cups, tableware, etc.).
Complementary methods: spectrophotometry, titration, gravimetry
Other methods can complement chromatographic and spectrometric techniques depending on the objectives of the analysis or the resources available:
- UV-Vis spectrophotometry : a rapid method for estimating the concentration of substances absorbing in the UV (formaldehyde, phthalates, dyes).
- Acid-base titration : still used for simple substances or for routine controls (acetic acid, ion migration).
- Gravimetry : reference technique for global migration, consisting of evaporating the simulant and weighing the remaining residues.
These techniques, although simpler, remain standardized and very useful in routine analyses, particularly in internal laboratories of certain industries.
Example of a protocol inspired by tests on malic acid
To illustrate the rigor of migration analyses, we can look to a protocol used to measure the concentration of malic acid in food products, which is also used in materials analysis:
- Sample preparation : extraction in an aqueous or alcoholic simulant.
- Filtration : removal of particles and stabilization of the solution.
- Analysis by HPLC : separation and UV detection at 210 nm.
- Quantification : comparison with a calibration curve.
- Compliance check : comparison with established migration thresholds.
This type of protocol, common to specialized laboratories, demonstrates how analytical expertise is for ensuring the safety of food packaging. The techniques used in migration tests are identical to those employed to analyze food additives, pesticide residues, or environmental contaminants.
YesWeLab provides manufacturers with simplified access to these advanced technologies , leveraging a network of partner laboratories equipped with the latest generation of analytical instruments. This approach combines scientific expertise, compliance with standards, and operational efficiency.
Migration tests: which materials are involved?
All materials intended to come into contact with food can potentially release substances into the food, depending on their chemical composition, structure, or surface treatments. Therefore, migration tests are not limited to plastics but encompass a wide range of materials used in food packaging, processing, and presentation. Each type of material has specific analytical and regulatory requirements that must be understood to ensure consumer safety.
Plastic materials
Plastics PP , PVC, PS…) and contain many additives: plasticizers, antioxidants, stabilizers, pigments, antistatic agents.
These materials are governed by Regulation (EU) No 10/2011 , which requires:
- A positive list of permitted substances,
- and specific migration limits ,
- The obligation to establish a declaration of conformity .
Migration tests on plastics are essential to check for the presence of residual monomers , phthalates , bisphenol A , or nano-additives in new materials.
Special features:
- Materials are often multi-layered, with barrier or adhesive layers,
- Migration is influenced by the type of food (fatty, acidic), temperature, and duration of contact.
- Frequent use of oily or alcohol-based simulants .
Metals and alloys
Metals aluminum , stainless steel, tin, etc.) are used in canned goods, tins, bottle caps, and kitchen utensils. The risks of migration include, in particular:
- Heavy metals ( lead, cadmium, nickel),
- Interior coatings ( lacquers, varnishes) which can degrade over time.
These materials must meet strict requirements regarding corrosion and chemical resistance . Specific migration tests aim to quantify metallic elements according to the limits defined by Directive 2002/72/EC , Directive 84/500/EEC Council of Europe guidelines for metals in contact with food.
Special features:
- ICP-OES analysis to quantify metals,
- Migration tests were performed using 3% acetic acid to simulate an acidic food.
- Importance of surface condition (oxidation, polishing, coatings).
Paper, cardboard and wood
Paper and cardboard are increasingly used to replace plastics, particularly in single-use packaging. Although perceived as more environmentally friendly, these materials can contain:
- Synthetic glues or binders ,
- Barrier inks or coatings ( PE , varnish),
- Manufacturing residues (bleach, solvents, PFAS).
The European regulatory framework for these materials is not yet harmonized at the EU level, but some Member States (France, Germany, the Netherlands) have implemented their own requirements. In the absence of specific European regulations, Framework Regulation (EC) No 1935/2004 remains the reference basis.
Wood , used for cutting boards, cutlery or specific packaging, is also affected, particularly when it is treated or varnished .
Special features:
- Migration tests are necessary for recycled materials.
- Potential presence of unintentionally added substances (NIAS) ,
- Increased monitoring of PFAS , even in the absence of specific migration limits.
Inks, glues, varnishes and adhesives
Printing inks , glues , varnishes , and adhesives are ubiquitous in packaging, particularly for labels, printed lids, multilayers, and closure systems. They contain numerous ingredients: solvents, photoinitiators, resins, pigments, and curing agents.
Even if they are not in direct contact with the food, migration phenomena by diffusion or reverse migration can occur, particularly through permeable materials or by transfer during stacking.
Specific migration tests are therefore essential for:
- Detect aromatic amines , photoinitiators , acrylics , residual solvents ,
- Evaluate volatile organic compounds (VOCs) ,
- Verify compliance with good manufacturing practices (GMP) as provided for in Regulation (EC) No 2023/2006 .
Special features:
- Use of mixed or fatty simulants depending on the conditions of use,
- Advanced analysis using GC-MS , HPLC-UV , or spectrophotometry ,
- Evaluation is necessary from the design stage of printed materials.
Ceramic, glass and enamel materials
Inorganic materials such as glass, ceramics, and enamel are used in tableware, dishes, jars, and cooking containers. Although they are perceived as stable, they can release certain toxic elements upon contact with food, notably lead or cadmium , particularly in decorated or colored items.
These materials are regulated by Directive 84/500/EEC , which sets limits on the migration of heavy metals from ceramic materials.
Special features:
- Tests performed with 4% acetic acid at 22°C for 24 hours,
- Migration expressed in mg/dm² or in mg per article,
- The need to control handcrafted or imported goods, which are often non-compliant.
Interpretation of migration results
Performing a migration test is a crucial step, but it's equally important to know how to correctly interpret the results to draw reliable conclusions and make appropriate regulatory or industrial decisions. This section aims to explain how the data from the analyses is used, what compliance thresholds must be met, and what actions can be taken if permitted limits are exceeded.
Regulatory compliance criteria
Migration test results are generally expressed in mg/kg of feed or mg/dm² of material . They must be compared to the maximum migration limits defined by applicable regulations, primarily:
- Regulation (EU) No 10/2011 on plastics,
- Regulation (EC) No 1935/2004 for all materials in contact with food,
- Directive 84/500/EEC for ceramics and glass,
- FDA guidelines for materials marketed in the United States.
Common regulatory limits:
- Overall migration : ≤ 10 mg/dm² of contact surface (or 60 mg/kg of food for articles intended for children),
- Specific migration : thresholds vary depending on the substance. For example:
- Formaldehyde: ≤ 15 mg/kg,
- Bisphenol A: ≤ 0.05 mg/kg (value significantly reduced in the EU),
- Lead (in ceramics): ≤ 0.8 mg/dm².
Each result is interpreted taking into account:
- The type of simulator used,
- The duration and temperature of contact ,
- From the surface area/volume ratio ,
- The type of material and its end use.
A material is considered compliant if all measured values are below regulatory thresholds . Otherwise, it is necessary to correct the formulation or restrict the use of the product.
Exceeding a threshold: what to do?
When a test reveals migration exceeding the permitted limit , the manufacturer cannot market their product as is. Several options are then available to rectify the situation:
- Material reformulation : replacing a problematic additive with a more stable or less migrating alternative,
- Design modification : addition of a barrier layer to limit the transfer of substances,
- Change of supplier : some materials may exhibit significant variations in quality.
- Reduction of usage time or temperature : for example, prohibiting the use of a container in a microwave oven if migration increases with heat,
- New analytical validation : after modification, new tests must be carried out to prove the conformity of the material.
It is also recommended to document each step of the correction process and to keep the analysis reports, in order to respond to any requests from the relevant authorities.
Unexpected Migrants: The NIAS
(NIAS ) pose a growing challenge in the interpretation of migration tests. These are undeclared substances , present unexpectedly in the material, for example:
- Manufacturing or polymerization residues,
- Thermal degradation products,
- Contaminants from recycling,
- Chemical interactions between components.
NIAS are not always included in regulatory lists and may not be associated with a specific limit. However, Regulation (EC) No 1935/2004 requires that any migrating compound be safe for health .
Recommended analytical strategy:
- Analytical screening by broad-spectrum GC-MS or LC-MS,
- Toxicological assessment based on toxicological concern thresholds (TCTs),
- Risk management approach related to the nature, exposure, and frequency of use.
YesWeLab offers advanced exploratory analyses to identify NIAS and assess their potential impact on product safety.
Traceability and regulatory documentation
One of the main objectives of migration testing is to provide objective proof of compliance . The results must be included in a technical report , which is usually required by clients, quality auditors, or regulatory authorities.
This file must include:
- The manufacturer's or transformer's declaration of conformity
- The analysis report from the accredited laboratory (including conditions, results, and standards),
- Traceability of raw materials and additives used,
- Safety data sheets for potentially migrating substances.
In the event of an inspection, this file constitutes proof of due diligence and demonstrates that the manufacturer has taken all necessary precautions to guarantee the safety of its packaging.
