Everything You Should Know About Safety Regulations for Food Contact Materials

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Food Contact Materials play an important role in the food supply chain by protecting food against contamination during storage and transportation. However, they have the potential to transfer several harmful chemicals into food. Therefore, an effective control system for FCM is critical to ensure the safety of food products throughout their shelf-life.


Food contact materials must not release substances to food in quantities that can be harmful to health. Producers and importers of food contact materials must ensure and document that their food contact materials comply with this and other legislative requirements. In this article, we’ll address the five biggest questions related to global food contact material compliance that help ensure compliance and consumer safety.


Are Safety Regulations for Food Contact Materials Significant?

Food contact material compliance is an essential part of a risk management system. When it comes to the FCM regulations, the reason for their existence is consistent across the board.


·         First, legislation exists to keep humans safe by ensuring chemicals from packaging materials do not leach into the food in hazardous concentrations.

·         Second, FCM should not adversely affect the sensory properties of food. Think about it—when opening cashews packaged in plastic, what should the consumer be tasting? If they’re tasting plastic, their experience has been compromised, and they will immediately question the safety of the food.

·         Finally, a commonality among regulations is that FCM should be manufactured using Good Manufacturing Practices (GMPs).


The GMPs tend to be broad (or general) in nature, but ultimately, the intent is to ensure that materials are manufactured in a quality-controlled environment with acceptable hygiene controls in place. To make it even more difficult, the regulations all vary enough to cause significant confusion in the industry.


Requirements for testing food packaging materials are different across the various regulations. But one thing is consistent: generally, real food is not used when testing for migration and extraction. Because it is impossible to create consistent and reproducible food from actual food, FCM testing globally depends on food simulants (substances that mimic food) to show accurate results. Common stimulants include ethanol, acetic acid, and vegetable oil.


Regardless of which regulation materials are being tested, the maximum food contact temperature and time in contact with the actual food are needed to test accurately. For example, packaging for ice cream should not be tested at boiling temperatures, as it is not intended for use in that environment.


Who Regulates Food Contact Materials Anyway?

Another general commonality from regulation to regulation is that the burden of proof is really at the formulator level. Ideally, the material formulator has reviewed its compositions to the regulations and can tell its consumers whether or not it complies. How do formulators communicate this? Through a self-declaration, or a Declaration of Compliance (DoC), that may or may not also include some test data.


The final product manufacturer gathers up all these declarations and determines if further testing is necessary. Perhaps the material was never tested at the temperature of the intended food, or with the correct simulant. Either way, the final product manufacturer also ends up testing the material to ensure compliance for its end customer, the food manufacturer.


The packaging manufacturer will then create its own DoC, accompanied by its testing, to show compliance with the overall packaging material. Some countries may have registration requirements or labeling requirements, but all the material testing and formulary review are done by the manufacturer and verified by customs, in the field, or maybe not at all.


Food contact material compliance is an essential part of a risk management system. As you swim through the sea of alphabet soup and regulatory nuances, remember that although regulations are complex and adherence is often time-consuming, the intent is the same across the board: keeping people safe.



The Essence of The Brennan Group’s Food Contact Materials Testing

Consumers are increasingly vigilant when it comes to the safety of food contact materials. Many countries have adopted rigorous regulations and standards to help ensure the safety and quality of food contact materials.


We support manufacturers in their drive to protect public health and to comply with rigorous industry regulations and standards to bring safe and high-quality food contact materials to the market.


Your first choice in navigating the global regulatory landscape

With our safety science expertise, independent objectivity, and data-driven approach, we can help guide your decision-making process. We will assist you in navigating the necessary compliance regulations for exporting food contact materials to your target markets.


At The Brennan Group, we offer to test for a wide variety of food contact materials to serve your needs better.


Food contact materials list:

·         Preparation surfaces – cutting boards, tables, stations, etc

·         Containers – cups, mugs, boxes, etc

·         Cookware and kitchenware, etc

·         Utensils – spoons, forks, knives, etc

·         Packaging – bags, laminates, films, foils, etc

·         Contact appliances – toasters, roasters, kettles, coffee machines, etc



Achieve compliance for food-related materials with chemical and physical testing

By providing a comprehensive range of physical and chemical migration testing for your food contact materials, we help you through the compliance process and enable you to launch your food contact materials product on time.

Chemical migration analysis services


Molecules can migrate from food contact materials, endangering human health, bringing about unacceptable changes in the composition of food, or deteriorating its organoleptic characteristics.


Food contact materials and articles must be manufactured so that they do not transfer elements to food in measurable quantities. 


We offer analysis services for:

·         Overall migration by various simulants

·         Specific migration of various monomers (e.g., vinyl chloride monomer, formaldehyde, melamine)

·         Specific migration of heavy metals

·         Specific migration of primary aromatic amines (PAA)

·         Sensorial testing


Physical testing services 

·         Dishwasher, microwave, and oven safe

·         Fatigue, corrosion and heat resistance

·         Thermal hazards

·         Paints and varnishes cross-cut


We support brands and retailers in creating customizing inspections, audits and training programs that address numerous needs during all stages of the supply chain, from developing a product to efficiently getting it onto shelves in your target markets.


A Verified Mark for Food Contact Materials

Customers around the globe demand more transparency from the products they choose. With scientific rigor, The Brennan Group evaluates the validity of specific advertising or promotional statements. Inside our laboratories, we apply scientific methodologies to verify your products provides the following types of claims: 100% stainless steel, 100% wood, plastic-free, and non-stick. 


The Verified Mark helps set your product apart in the marketplace and increase credibility to your product claims. Communicate truth and transparency on your product labels through our marketing claim Verification program to give your customers greater peace of mind.



Food Contact Materials and Food Safety Regulations: How Does It Work?

Food contact materials (FCMs) are exactly that: materials that are in contact with food or potable beverages during processing, packaging, or storage. This includes parts in machinery used for food processing, even covering such things as coffee machines and drink dispensers. Food contact materials and food contact substances (FCS) mean the same thing.


During the contact, molecules from materials can migrate into foods or beverages. Because of this, most countries have food safety regulatory agencies that monitor materials for food safety. In the United States, the most recognized and frequently encountered food safety agency is the FDA. NSF International is the most recognized food safety standards organization.


Food Safety Management System and Documentation

Producers and importers of food contact materials must provide a declaration of compliance for their food contact materials together with additional supporting information on their food safety management system including e.g. migration test results.


The food safety management system in food contact material establishments must be following the requirements in EU regulation 2023/2006 on good manufacturing practice (GMP).


Legislation on food contact materials (FCM)

Most legal requirements for food contact materials are harmonized within the EU. Additionally, Ireland has national legislation on:

·         A ban on the marketing of paper and board FCM in which per- and polyfluorinated alkylated substances have been used

·         Migration of lead and cadmium from glass and other ceramic products besides ceramic, including requirements for migration from the mouth rim

·         A positive list of surface biocides for plastic FCM

·         The declaration of compliance, which is required for all types of food contact materials


To ensure the use of safe food packaging, food industries should be able to identify the compliance of FCM with this guideline.


All FCM shall be manufactured in compliance with good manufacturing practice (GMP) so that under normal or foreseeable conditions of use, the FCM does not transfer their constituents to food in quantities which could:

·         Endanger human health

·         Bring about an unacceptable change in the food

·         Bring about unacceptable changes in the organoleptic characteristics thereof.


The safety of FCM should be determined by the risk assessment of substances. FCM authorized by national/regional authority may be considered to be safe upon review of relevant risk assessment results and/or of approvals granted by the relevant national/regional authority. Substances used in the manufacture of FCM and FCM in its finished state shall comply with the requirements applicable in the market.


Food packaging and food packaging materials should be safe and should not transfer their components into food in unacceptable quantities. It defines fundamental requirements for food packaging and other food contact materials. Thus, food packaging materials shall not transfer their ingredients to food in quantities that may endanger human health.


The migration of toxicological substances must not exceed certain limits. Additionally, food packaging may not bring about an unacceptable change in the composition of the food, which is generally understood as overall migration and food packaging may not deteriorate aroma or taste.




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