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How to minimise the number of migration tests for plastic packaging?

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Adawiyah

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Posted 16 March 2020 - 09:15 AM

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?

 



pHruit

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Posted 16 March 2020 - 09:40 AM

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.



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Charles.C

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Posted 16 March 2020 - 09:46 AM

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.


Kind Regards,

 

Charles.C


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Adawiyah

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Posted 17 March 2020 - 01:14 AM

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?



Charles.C

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Posted 17 March 2020 - 07:42 AM

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.

Attached File  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)

Attached File  FDA, functional barrier.pdf   173.6KB   20 downloads


Kind Regards,

 

Charles.C




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