Food Contact Migration Testing — Simulants, Time & Temperature
A migration study evaluates substances transferred from a food-contact article under defined exposure conditions. A defensible request specifies the material, intended food types, temperature, contact duration, repeated use and market before the laboratory chooses analytical methods.
Write the intended use before the test plan
A chilled single-use tray, hot-fill bottle and repeatedly used utensil expose materials differently. Identify food types and contact conditions as supplied and as reasonably used. FDA's chemistry guidance discusses migration cells, test samples, simulants, time and temperature, analytical methods and reporting. It is guidance for a defined regulatory context, not a universal protocol for every article or destination market.
Distinguish overall, specific and investigative work
Overall migration and compound-specific migration address different requirements where applicable. A formulation review can identify substances with relevant restrictions and analytical targets. Non-intentionally added substance investigations may need an additional risk-based analytical and interpretive plan rather than an unqualified untargeted scan. Ask what the lab can quantify, how reference standards and matrix effects are handled, and which unidentified findings require specialist assessment.
Represent the actual article
Use finished material with its relevant coatings, printing, adhesives and processing history. Agree exposed surface, food-contact side, sealing arrangement and surface-area basis, especially where a cell could expose cut edges not present in use. State whether the work is a compliance test, comparison, troubleshooting study or evidence for a submission. Changes in suppliers or layer construction may require the plan to be revisited.
Keep testing and authorization separate
The report should give conditions, analyte list, quantification limits, recovery, calculations and deviations, not only a pass/fail statement. FDA explains that food-contact notifications apply to specific notifiers and uses; a result cannot transfer an authorization to an unrelated supplier. Confirm the applicable EU or US legal basis with the responsible specialist. Select the lab by documented matrix and method scope and agree interpretation responsibilities.
Sample considerations
- Supply material composition and layer drawings under confidentiality, authorization references and finished specimens.
- Declare food types, time/temperature, repeated-use conditions, contact side and target market.
- Agree specimen preparation, blanks, exposure geometry, target compounds and report basis before cutting.
Questions to ask a laboratory
- Which legal measure and intended-use conditions justify these simulants and exposures?
- Will edges, layers or cell seals create exposure unlike actual use?
- Which analytes and limits are validated for this matrix, and who interprets unidentified substances?
Laboratories with relevant capabilities
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Sources and scope references
FDA — food-contact chemistry and migration study guidance
FDA — authorization and notifier-specific limitations
Related testing briefs
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