Product compliance · Migration + DoC + 1935/2004
Food-contact materials
Migration testing, declarations of compliance and the EU framework rules for plastics and other materials.
Key facts
| EU route | Framework Regulation 1935/2004; plastics under 10/2011 |
|---|---|
| US route | FDA food-contact notification or listing |
| UK route | Retained EU food-contact rules and declarations |
| Core tests | Overall and specific migration; sensorial testing |
| Key documents | Declaration of compliance, migration reports, MSDS |
| Recurring | Supplier declarations and reformulation checks |
| Typical one-off budget | USD 400–2,500 per material and use case |
| Last verified | 2026-10-17 |
The use case decides the test
A food-contact material is assessed against the food type, the temperature and the contact time it is designed for. A cold-drink bottle and an oven tray made from the same polymer can need different migration testing and different declarations. The file has to state the intended use, not just the material.
Recycled content and multi-layer structures add questions about the source and the functional barrier. A supplier declaration that only names the resin is not enough for a finished article.
The declaration travels with the goods
In the EU, a declaration of compliance accompanies food-contact materials, and the business customer is entitled to the supporting information. The declaration is not a one-time marketing document; it has to match the article, the materials and the intended use.
The US route depends on the substance: some materials are covered by prior sanction or a food-contact notification, others need a notification. The same article can therefore be simple in one market and slow in another.
Frequently asked questions
Is a migration test valid for every food type?
No. The test conditions depend on the food category, temperature and contact time. The declaration should state which conditions it covers.
Do I need a new declaration when I change suppliers?
Yes, if the material or the process changes. The declaration has to describe the article actually being supplied.
Does food-contact compliance apply to packaging only?
It applies to articles intended to contact food, including packaging, tableware, storage containers and processing equipment.
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