How to minimise the number of migration tests for plastic packaging?
I have a question regarding migration tests. My company produce plastic packaging for food with several structure layer. Our customer always ask us for migration test report. The problem is, we not test all of our plastic packaging product due to cost and we had almost 20 different material structure. for example:
- PET/ PE/ Foil/ LLDPE
- PET/ LLDPE
Based on the above structure, LLDPE is the material which is directly contact with food. And, we had done migration test for PET/ LLDPE.
My question is:
If customer request us migration test for PET/ PE/ Foil/ LLDPE, can we give our customer migration test result of PET/ LLDPE?
If customer request us migration test for PET/ PE/ Foil/ LLDPE, can we give our customer migration test result of PET/ LLDPE?
We buy multilayer packaging just like this, and the test results I expect to see from our suppliers relate to the LLDPE layer that is in contact with the food. The remainder are inconsequential if they are demonstrably not going to have contact (including incidental contact) with the product, so I think your position is entirely reasonable.
You may need to talk it through with your customer(s) just to make sure they've understood, or if it's a question you get a lot then you could put together a brief information statement explaining it.
I have a question regarding migration tests. My company produce plastic packaging for food with several structure layer. Our customer always ask us for migration test report. The problem is, we not test all of our plastic packaging product due to cost and we had almost 20 different material structure. for example:
- PET/ PE/ Foil/ LLDPE
- PET/ LLDPE
Based on the above structure, LLDPE is the material which is directly contact with food. And, we had done migration test for PET/ LLDPE.
My question is:
If customer request us migration test for PET/ PE/ Foil/ LLDPE, can we give our customer migration test result of PET/ LLDPE?
Hi Adawiyah,
Not my area but the relevant question is presumably whether the migration characteristics (to the food) of the two items are equal ?
Offhand, seems improbable to me but I guess fairly easy to test one representative sample.
Can see the files in this post -
https://www.ifsqn.co...ng/#entry154728
The (EU) situation appears to also relate to whether a "functional Barrier" is present.
Hi Adawiyah,
Not my area but the relevant question is presumably whether the migration characteristics (to the food) of the two items are equal ?
Offhand, seems improbable to me but I guess fairly easy to test one representative sample.
Can see the files in this post -
https://www.ifsqn.co...ng/#entry154728
The (EU) situation appears to also relate to whether a "functional Barrier" is present.
Hi Charles.
Thanks for your respond. Let's say, migration test result of PET/ LLDPE is 'ND'. Means, no migration detected. What do you think? Because no migration detected in our record for the items we test.
In EU 10/2011 Article 14
By derogation from paragraph 1, in a multi-material multi-layer material or article a plastic layer which is not in direct contact with food and is separated from the food by a functional barrier, may be manufactured with substances not listed in the Union list or the provisional list.
How we can declare functional barrier in my case? for example available of Foil in the structure?
Hi Charles.
Thanks for your respond. Let's say, migration test result of PET/ LLDPE is 'ND'. Means, no migration detected. What do you think? Because no migration detected in our record for the items we test.
In EU 10/2011 Article 14
By derogation from paragraph 1, in a multi-material multi-layer material or article a plastic layer which is not in direct contact with food and is separated from the food by a functional barrier, may be manufactured with substances not listed in the Union list or the provisional list.
How we can declare functional barrier in my case? for example available of Foil in the structure?
Hi Adawiyah,
Any suggestions may be superceded by any existing Local Packaging Regs (assuming this item is used locally).
Generally I noticed these comments -
Thus, we can distinguish between absolute and partial barriers. Some materials, such as glass (any thickness) or certain metals (e.g., aluminium foil ≥ 8 µm thickness), are able to ensure complete blockage of migration.
Functional barriers in multi-layer food packaging,2017.pdf 2.45MB 23 downloads
FDA has not provided a lot of explicit guidance concerning functional barriers, although the Agency has stated that aluminum foil and 1 mil (25 micron) thick PET layer intended for use under room temperature conditions constitute functional barriers (see 21 C.F.R. Section 177.1390(a) and FDA’s Recycled Plastics Guidance, respectively)
FDA, functional barrier.pdf 173.6KB 20 downloads