Food Contact Material Testing

Accredited Laboratory Testing Services Ensuring Regulatory Compliance for Food Contact Materials and Articles

Food packaging is one of the most critical elements in ensuring that a product reaches the consumer safely. Packaging is not only a means of physically protecting food, but also an integral part of product safety as a material intended to come into direct or indirect contact with food. Therefore, packaging safety represents not only the responsibility of protecting consumer health, but also a legal and commercial obligation for manufacturers and brand owners. In order to fulfil these responsibilities, packaging testing is an essential requirement.

From a technical perspective, food contact materials and articles include all packaging materials, containers, closures, processing equipment, and ancillary materials that come into direct or indirect contact with food. This scope includes:

• Plastic packaging
• Paper and cardboard packaging
• Metal and metal-coated products
• Glass, ceramics, and porcelain
• Silicone and elastomer-based materials
• Multi-layer and recycled materials

covering a wide range of products.

The Turkish Food Codex and European Union legislation clearly require that food contact materials and articles must not alter the composition of food, pose a risk to human health, or adversely affect the sensory properties of food, such as its taste, odour, and appearance. Demonstrating compliance with these requirements is possible through packaging testing, particularly migration testing, supported by accredited test reports. At this point, the most important factor in enabling manufacturers to effectively manage their responsibilities is cooperation with the right laboratory.

The Importance of Packaging and the Responsibilities of the Manufacturer

Food contact packaging protects food against environmental influences throughout the period from production to consumption while remaining in continuous interaction with the food. Plastic, paper and cardboard, metal, glass, ceramic, silicone, and multi-layer packaging materials each present different risk profiles.

From a regulatory perspective, manufacturers are responsible for demonstrating that:

• the packaging is safe;
• it complies with migration limits;
• it is suitable for its intended conditions of use; and
• the Declaration of Compliance (DoC) is supported by analytical data.

Accordingly, the following requirements must be fulfilled:

• Use of suitable raw materials
• Migration testing (performed by an accredited laboratory)
• Preparation of a Declaration of Compliance (DoC)
• Maintenance of technical documentation
• Submission of documentation during inspections

These responsibilities continue not only when the product is placed on the market, but also during regulatory inspections, customer audits, and export processes.

What is Migration?

Migration is the transfer of chemical substances present in the structure of packaging materials into food under certain conditions. This transfer varies depending on factors such as:

• Temperature
• Contact time
• Type of food
• Structure of the packaging material

For this reason, migration testing is not performed in the same way for every type of packaging.

The Most Common Problems Faced by Manufacturers

Most of the issues encountered during routine operations and regulatory inspections are centred around the following point:

“A test report exists, but it does not represent the actual conditions of use of the product.”

The most common problems faced by manufacturers include:

• Standard test packages that do not reflect the actual conditions of use of the product
• Migration tests performed using the wrong food simulant, incorrect temperature, or incorrect contact time
• Analyses performed by non-accredited laboratories
• A Declaration of Compliance (DoC) that is inconsistent with the test reports
• Inability to provide a clear answer during an inspection to the question, “Why was this test performed?”

Even if testing has been carried out, these situations may result in a risk of non-compliance from a regulatory perspective.

Managing Risks Through Packaging Testing

Packaging testing should not be regarded merely as a list of analyses; it should form part of a system through which manufacturers manage regulatory compliance. Accordingly, packaging testing should be planned based on:

• The structure of the food contact material or article
• The type of food
• The contact temperature and contact time
• The target market (Türkiye, the European Union, etc.)

Why Choose Us? – Our B2B Laboratory Approach

At Bilim Laboratories, we approach packaging testing not as a standard testing package, but through a product-specific and risk-based approach.

This approach is based on the following principles:

• Not simply performing tests, but performing the right tests
• Not simply issuing documents, but ensuring that the documentation is technically defensible
• Establishing a system that does not create unexpected issues during inspections

What Do We Do?

We evaluate your products in accordance with:

• European Union legislation
• The Turkish Food Codex

and support them with the appropriate testing and documentation.

Our objective is to establish a clear, defensible compliance structure that progresses smoothly during regulatory inspections and customer audits.

How Do We Work?

Product-Specific Evaluation

Every product has different conditions of use. Therefore, we first determine:

• the food contact scenario,
• the contact temperature and duration of use, and
• the target market.

Based on this evaluation, we determine the applicable legislation and the scope of testing required.

What Does This Provide for You?

• No unexpected issues during regulatory inspections
• The ability to provide clear answers to technical questions
• Consistent and up-to-date documentation
• Regulatory compliance maintained under control

Who Is It For?

• Food packaging manufacturers
• Brand owners and private label manufacturers
• Food manufacturers
• Quality assurance and purchasing teams

Our Packaging Testing Services

Material Identification Analysis

“The first step towards accurate migration testing is accurate material identification.”

FT-IR Material Identification Analysis is a fundamental step in verifying the polymer type and material structure of food contact materials and articles. This verification ensures the correct selection of migration tests. In order to properly plan migration analyses and other packaging tests, it is necessary to analytically demonstrate that the tested sample corresponds exactly to the declared material.

Through FT-IR analysis, polymer types such as polypropylene, polyethylene, and polystyrene can be reliably identified. This helps prevent incorrect material declarations, inappropriate test selection, and the risk of reports being considered invalid during regulatory inspections. Therefore, FT-IR Material Identification is not only a characterisation test but also a critical verification step that ensures migration analyses are carried out in compliance with regulatory requirements, are technically defensible, and are consistent with the Declaration of Compliance (DoC).

As Bilim Laboratories, we provide Material Identification Analysis services for Food Contact Plastic, Silicone, Paper and Cardboard Materials and Articles.

Overall Migration Analyses

Migration analyses verify the transfer of substances from packaging into food and form the basis of packaging safety.

Overall migration tests determine the total amount of substances that may migrate from packaging into food. These tests are performed:

• Using aqueous, acidic, fatty, and alcoholic food simulants,
• Taking into account the actual conditions of use, including contact temperature and contact time,
• In accordance with the TS EN 1186 series of standards,
• In a laboratory accredited to TS EN ISO/IEC 17025.

Migration tests performed under incorrect conditions may be rejected during regulatory inspections, even if the analytical results comply with the applicable limits.

We provide a comprehensive scope of Overall Migration Testing for Food Contact Plastic Materials and Articles.

Metal Migration Analyses

Metal migration analyses are particularly required for:

• Pigment-containing plastics,
• Recycled (PCR/PIR) packaging,
• Coated and varnished surfaces,
• Materials with a risk of metal contact during production.

Within the scope of our accredited packaging testing services, we perform metal migration analyses in full compliance with the applicable legislation.

Food Contact Plastic Materials and Articles

Barium (Ba), Cobalt (Co), Copper (Cu), Iron (Fe), Lithium (Li), Manganese (Mn), Zinc (Zn), Aluminium (Al), Nickel (Ni), Antimony (Sb), Arsenic (As), Mercury (Hg), Cadmium (Cd), Chromium (Cr), Europium (Eu), Gadolinium (Gd), Lanthanum (La), Terbium (Tb), Lead (Pb), Calcium (Ca), Magnesium (Mg), Potassium (K), Sodium (Na)

Food Contact Paper and Cardboard Materials and Articles

Arsenic (As), Mercury (Hg), Cadmium (Cd), Lead (Pb)

Food Contact Ceramic, Porcelain and Glass Materials and Articles

Lead (Pb) and Cadmium (Cd)

These analyses are among the areas most frequently evaluated during inspections conducted under the Turkish Food Codex.

Food Contact Metal Materials and Articles

Tin (Sn), Arsenic (As), Cadmium (Cd), Chromium (Cr), Lead (Pb), Antimony (Sb), Aluminium (Al), Zinc (Zn), Copper (Cu), Mercury (Hg), Iron (Fe), Silver (Ag), Cobalt (Co), Magnesium (Mg), Manganese (Mn), Nickel (Ni), Titanium (Ti), Barium (Ba), Beryllium (Be), Molybdenum (Mo), Lithium (Li), Vanadium (V), Thallium (Tl)

CONCLUSION

Packaging Safety is a Manageable Process

Packaging analyses are indispensable for ensuring the safety of food contact materials and articles, complying with the requirements of the Turkish Food Codex, and enabling manufacturers to manage their responsibilities.

With the right laboratory partnership:

• Migration analyses are performed for their intended purpose;
• The Declaration of Compliance (DoC) is robust and consistent;
• Complex issues such as NIAS are managed correctly (described in the Additional Information section).

As Bilim Laboratories, we continue to be a reliable solution partner for our customers by providing packaging analyses with a regulatory and inspection-focused approach rather than a measurement-focused approach.

Additional Information

Specific Migration and a Formulation-Based Approach

Performing the same specific migration tests for every packaging material is not the correct approach. Specific migration tests:

• Are determined based on the formulation;
• Are based on additives, monomers, and catalysts;
• Require risk-based planning.

This approach enables:

• The avoidance of unnecessary analytical costs;
• Ensuring that critical substances are not overlooked;
• Alignment of test results with the Declaration of Compliance (DoC).

Information on NIAS (Non-Intentionally Added Substances)

NIAS is becoming an increasingly important topic in relation to food contact materials and articles. In particular:

• Recycled packaging,
• Pigmented and multi-layer materials,
• Products intended for use at high temperatures

present a higher risk with respect to NIAS.

However, NIAS is not an issue that can be resolved by the laboratory alone.

The Correct NIAS Model: Consultant–Laboratory Collaboration

The correct model for the NIAS process, accepted during regulatory inspections, is as follows:

• Laboratory: Performs analytical measurements and generates data.
• Consultant: Interprets the data and performs the risk assessment.
• Manufacturer: Issues the final Declaration of Compliance.

As Bilim Laboratories, although we do not provide final interpretations or regulatory decisions regarding NIAS, we recommend that the process be carried out under the supervision of a qualified consultant. This transparent allocation of responsibilities establishes documentation that is technically defensible during regulatory inspections.

Comparison of Overall Migration, Metal Migration, and Specific Migration

Note: While overall migration forms the basis of packaging analyses, specific migration and metal migration tests are planned according to the structure of the product and its intended conditions of use. The correct combination of these analyses ensures both regulatory compliance and that the Declaration of Compliance (DoC) is technically defensible during inspections.

Frequently Asked Questions

Are packaging analyses mandatory?

Yes. Packaging analyses for food contact materials and articles are mandatory under the Turkish Food Codex and the relevant European Union legislation. The manufacturer is responsible for demonstrating, through analytical testing, that the packaging does not transfer harmful substances into food and is safe under its intended conditions of use.

Is an overall migration test sufficient?

No. The overall migration test is the fundamental analysis used to evaluate the overall safety of packaging; however, it does not cover all risks on its own. Depending on the formulation, manufacturing process, and intended conditions of use of the packaging, specific migration and metal migration tests may also be required.

Are test reports issued by non-accredited laboratories accepted?

Generally, no. During inspections conducted under the Turkish Food Codex and customer audits, test reports issued by laboratories accredited to TS EN ISO/IEC 17025 are generally required. Otherwise, even if the analytical results comply with the applicable limits, the reports may be considered invalid during inspections.

Is NIAS required for every type of packaging?

No. The evaluation of NIAS (Non-Intentionally Added Substances) is particularly relevant for recycled, pigmented, or multi-layer packaging materials. NIAS is not an automatic test for every type of packaging; it should be considered based on a product-specific risk assessment.