Exploring Food Contact Materials Migration Testing for Kitchenware

First published::
May 2025

Food contact materials (FCMs) are essential in ensuring food safety and quality, from packaging to utensils and processing equipment. However, these materials can sometimes release harmful substances into food, posing potential health risks. Migration testing is a critical process that helps ensure that kitchenware and other FCMs do not transfer harmful chemicals into food, protecting consumers from potential hazards.

In this article, we will explore the significance of migration testing for food contact materials, the types of testing available, and how Eurofins Softlines & Hardlines can assist businesses in ensuring the safety and compliance of their products.

What Are Food Contact Materials (FCMs)?

Food contact materials refer to any materials or objects that come into direct contact with food or beverages. Kitchenware, which includes utensils, cookware, and storage containers, falls under this category and must meet strict safety regulations to prevent harmful chemical migration.

Common Kitchenware FCMs: 

• Plastics: Used in cutting boards, food storage containers, and utensils.
• Metals: Found in cookware such as pots, pans, and cutlery.
• Ceramics & Glass: Used in plates, bowls, and baking dishes.
• Silicone & Rubber: Found in baking mats, spatulas, and food molds.
• Wood & Bamboo: Used for cutting boards and utensils.

While these materials are essential for food preparation and storage, they must comply with stringent safety standards to ensure they do not release harmful substances into food.

Key Regulatory Standards for FCMs

FCMs are strictly regulated to ensure they are safe for use. Some key regulations include:

European Union (EU)

• Regulation (EC) No 1935/2004 – General framework regulation for all FCMs, ensuring they do not release harmful substances into food.
• Regulation (EU) No 10/2011 – Specific rules for plastic food contact materials, including migration limits for certain substances.
• Regulation (EC) No 2023/2006 – Good Manufacturing Practice (GMP) regulation for FCM production.
• Directive 84/500/EEC – Safety requirements for ceramic materials in contact with food.
• Regulation (EU) No 282/2008 – Rules for recycled plastic materials intended for food contact.
• Directive 2007/42/EC – Regulations on regenerated cellulose films used for food packaging.
• Commission Recommendation 2017/84 – Guidance on monitoring mineral oil hydrocarbons (MOH) in FCMs.

United States

• FDA 21 CFR Part 170-199 – U.S. Food and Drug Administration (FDA) regulations covering different types of FCMs.
• 21 CFR 175 – Adhesives and Components of Coatings
• 21 CFR 176 – Paper and Paperboard Components
• 21 CFR Part 177 – Safety rules for specific polymers and plastics.
• 21 CFR Part 178 – Regulations on indirect food additives, including colorants and stabilizers.
• 21 CFR Part 181 – Prior-sanctioned food substances.
• Generally Recognized as Safe (GRAS) Substances – Materials that are exempt from full regulatory approval due to established safety records.
• Food Contact Notification (FCN) Program – Pre-market approval process for new food contact substances.
• FDA Threshold of Regulation (TOR) Exemptions – Allows some low-risk substances to be exempt from FDA review.

China

• GB 4806.1-2016 – General safety standard for FCMs in China.
• GB 9685-2016 – List of permitted additives for food contact applications.
• GB 31603-2015 – Good Manufacturing Practice (GMP) standards for FCMs.
• GB 4806 series – Specific standards for materials such as plastics, paper, coatings, rubber, and glass.
• GB 31604.1-2023 (General Rules for Migration Testing)

Japan

• Food Sanitation Act (FSA) – Governs food safety, including FCMs, with oversight by Japan’s Ministry of Health, Labour and Welfare (MHLW).
• Positive List System for FCMs (2020) – Only approved substances can be used in food contact plastics.
• JHOSPA Guidelines – Industry guidelines for plastic safety.

Canada

• Division 23 of the Food and Drugs Act and Regulations, Section B.23.001 (FDR) – Establishes safety requirements for materials in contact with food.
• Health Canada’s Letter of No Objection (LONO) – Approval process for new FCMs.
• Lists of acceptable polymers for use in food packaging applications

Why Is Migration Testing Essential for Kitchenware?

Migration testing ensures that kitchenware is safe for use and does not pose a risk to public health. It determines whether chemicals from materials like plastic, metal coatings, or ceramics migrate into food under normal usage conditions.

Key Risks of Migration in Kitchenware:

• Health Concerns: Harmful chemicals such as bisphenol A (BPA), phthalates, lead, and cadmium can migrate from cookware and utensils into food. These substances have been linked to endocrine disruption, developmental issues, and even cancer risks.
• Food Contamination: Migration can alter the taste, colour, or smell of food, affecting its quality.
• Regulatory Compliance: Ensuring kitchenware meets global food safety standards is essential for manufacturers and retailers.

For example, ceramic cookware must comply with lead and cadmium migration limits to prevent heavy metal exposure. Similarly, plastic kitchenware must be tested for specific chemical leaching under heat exposure.

Types of Migration Testing for Kitchenware

Migration testing evaluates how kitchenware interacts with food under various conditions. There are two primary types:

1. Overall Migration Testing

• Assesses the total amount of material that migrates from the kitchenware into food or food simulants.
• Ensures that migration remains below regulatory limits.
• Example: Testing a plastic food storage container for overall chemical leaching when exposed to heat.

2. Specific Migration Testing

• Focuses on individual harmful substances, such as BPA, phthalates, heavy metals, or formaldehyde.
• Example: Testing a non-stick pan for perfluorooctanoic acid (PFOA) migration.

These tests replicate real-life conditions, such as high temperatures, acidity levels, and prolonged food contact, to assess migration risks.

Preparing for Migration Testing: Key Considerations

Before submitting your FCMs for migration testing, it's important to ensure the materials meet the appropriate standards. Here are some steps to consider:

• Material Composition: Understand the materials used in your product and identify any chemicals that may migrate.
• Food Simulants: Select the correct food simulants based on the type of food the material will come into contact with (e.g., fatty foods, acidic foods, dry foods).
• Testing Conditions: Be aware of the testing conditions such as temperature and exposure time, which should reflect real-life usage scenarios.
• Documentation: Provide detailed information about the material, intended use, and regulatory requirements to guide the testing process.
• Proper preparation ensures that the testing process goes smoothly and provides accurate results.

The Future of FCMs and Migration Testing

The industry is evolving, with increasing demand for sustainable and environmentally friendly alternatives to traditional materials. Biodegradable and recyclable materials are gaining popularity, but these materials may present new challenges when it comes to migration testing.

As new materials are developed, migration testing will remain essential to ensure their safety. Additionally, with stricter regulations and heightened consumer awareness of food safety, companies will need to stay ahead of evolving standards to maintain consumer trust and compliance.

How Eurofins Softlines & Hardlines Can Help

Eurofins Softlines & Hardlines provides comprehensive migration testing services for food contact materials, ensuring compliance with international regulations and protecting consumer health.

What We Test: 

• Raw Materials: Ensuring safety from the outset.
• Intermediate Materials: Verifying safety during production processes.
• Finished Products: Ensuring the safety of final consumer-ready items.

Our EN ISO/IEC 17025:2018-accredited laboratories provide expert testing for food contact materials, ensuring compliance with both national and international standards, including MSZ, DIN, EN, ISO, and others. You can depend on us for:

• Global Expertise: With decades of experience in the field of testing and certification, Eurofins has established itself as a global leader in FCM testing. Our network of laboratories and experts allows us to deliver reliable and accurate testing worldwide.
• Comprehensive Testing: We offer both overall and specific migration testing for a wide range of materials, including plastics, metals, and paper-based materials.
• Regulatory Compliance: Eurofins stays up to date with global regulatory changes and ensures that your FCMs meet the latest standards set by regulatory bodies such as the EFSA and FDA.
• Quick and Reliable Results: Our state-of-the-art laboratories offer fast turnaround times and provide results that help manufacturers move forward with confidence.

Whether you're a manufacturer of food packaging, kitchenware, or food processing equipment, we can support you in ensuring that your products are safe and compliant.

Contact us today to learn more about how we can assist with your FCM testing needs. 

Watch the On-demand Webinar for More!

Watch our on-demand food contact materials webinar, where our experts cover key FCM regulatory updates and changes, how FCM testing ensures compliance with safety standards and real-life case studies.