If raw materials are suitable for food packaging is migration testing necessary?

Hi all, we are currently BRC Packaging materials-Issue 6 certified for non-contact food packaging and are now moving towards food contact. We are currently looking at raw materials, if all raw materials are suitable for food packaging is migration testing necessary? Kris

I'm not in packaging, but if you're using materials that fall within the scope of Reg (EU) 10/2011 then I can't see how you'd demonstrate compliance with this - i.e. showing that the material(s) meet the requirements of various Articles within that regulation - without doing the migration testing.

We are SQF food contact packaging and we test for migration. In my humble opinion, not many other ways to prove your raw material is doing it's  job if you don't.

I would definitely look into migration testing.

The object of a migration test is products, regardless what their materials qualify for. The detailed FS criteria differ from object to another object. 

Dear Kristina Lundy,

how is the definition for "suitable for food packaging"?

BRC follows/has to follow legal requirements...

If your supplier certifies such it should be based on testing or modelling/calculation for the product and application. And it is your responsibility to check whether additional testing/calculation is necessary.

At the end you as FBO are responsible for fulfilling the legal requirements fpor your product (food + packaging(s)). Don't rely on the (old) definition of primary, secondary, tertiary packaging. Example: gas transfer of mineral oil components from recycled fiber (box) through several layers (foil, tray) into food.

Rgds

moskito

Thank you all for your help. Does anybody know the costs involved migration testing?

Hi Kristina,

We are a flexibles packaging manufacturer manufacturing both food contact and non-food contact packaging and certified to BRCGS Packaging Issue 6 with AA Grade. Yes, it is important that you start with raw materials that are food contact compliant with FDA, EU, Japanese regulations etc depending on the country of manufacture and the country of use of the final product.

As you are going to process these raw materials - ie extrusion, printing, lamination etc, there is a transformation of your raw materials during manufacture. Therefore certifying bodies would expect you to do some migration testing to show due diligence that you comply with food contact regulations.

Our strategy is to check 2 or 3 products each year depending on the customer requests/demands and rotate these products from year to year so that we have covered as many products as possible over the years. We have done migration testing since 2013. There is a growing list of food contact regulations each year and the cost of migration testing depends on the parameters you test and testing organization you choose. It is not cheap. It could be 3000-4000 Euros for 2 products depending on the parameters you choose for testing.

Our auditors have never had an issue with our approach.

Hope this answers some of your queries.

Best regards

Lakmal

Our strategy is to check 2 or 3 products each year depending on the customer requests/demands and rotate these products from year to year so that we have covered as many products as possible over the years. We have done migration testing since 2013. There is a growing list of food contact regulations each year and the cost of migration testing depends on the parameters you test and testing organization you choose. It is not cheap. It could be 3000-4000 Euros for 2 products depending on the parameters you choose for testing.

 

Our auditors have never had an issue with our approach.

Hi Lakmal,

Your rotation strategy has me concerned a bit. There could be a product type not being checked within 3 years (a very common time period). How are you sure all your product categories are safe in term of migration hazard?

In my logic, one test sample only represents its type. For instance, a 2-layer PET-PE pouch cannot have migration properties of a 3-layer Nylon-MetPET-PE one (not mentioning thickness or lamination media). Assuming in 3 years you have 10 product types tested, does that cover all types the site produces?

Just share my thought.

Hi Lakmal,

Thank you for your reply. I should have said we produce printed carton board packaging sleeves and cartons.

Kristina

Hi Kristina,

I think most of the above replies are for plastics not sleeves & Cartons of Folding Box Board.

Reg (EU) 10/2011 is for plastic.

We do printed sleeves and cartons. We have taken information from all the suppliers (board, ink, varnish glue, foiling, window patching etc.)  to ensure the individual components are safe with regards to migration etc. We have done a risk assessment about the effects of combining the components with their individual contribution (will they react together? will they cumulate to be greater than allowed) and based on that we do not do migration testing. We have composed a declaration in line with the BRC clause 3.4.3. based on the information form the suppliers who have usually done migration on their components.

Hi Kristina,

I think most of the above replies are for plastics not sleeves & Cartons of Folding Box Board.

Reg (EU) 10/2011 is for plastic.

We do printed sleeves and cartons. We have taken information from all the suppliers (board, ink, varnish glue, foiling, window patching etc.)  to ensure the individual components are safe with regards to migration etc. We have done a risk assessment about the effects of combining the components with their individual contribution (will they react together? will they cumulate to be greater than allowed) and based on that we do not do migration testing. We have composed a declaration in line with the BRC clause 3.4.3. based on the information form the suppliers who have usually done migration on their components.

Hi Sharon,

Thank you for your reply. We have food safety certificates for our raw materials (board, ink, sett off powder, varnish and poly bags). Where do i start with information regarding combining components for a a risk assessment? Do you produce food contact packaging? 

Kristina

Hi Kristina,

Not a procedure as such Its a risk assessment.

What is the likelihood of a reaction? is the product put in the oven, microwave (I guess not) This could cause a reaction between the components.

Do the suppliers state ppm of migrating components/ heavy metals?

if so you can add the ppm of the ingredient /components and make sure they do not total above the threshold.

This may not be possible as some may be reported and not detected or below detection level.

If the detection level is 0.002 for example, in a worst case you could assume all components could be 0.002 (just below actually) if there are 3 components that would =0.006 ask is this now above the threshold?

Just applying logic. 

We are also a food contact paperboard packaging manufacturer and we do not perform and type of migration testing except for grease and that's more of a quality issue to determine how nasty a box is going to look 4 days after croissants have been sitting in it! All testing specs from your paperboard mfg should be reviewed and held as they perform the majority of performance testing as a sales / quality function.

Hi Beautiophile,

I agree with your concerns. Some of the manufacturers of packaging materials I know, do not carry out migration tests at all. It is also evident from some posts in this forum too. As long as we source our raw material from reputed approved suppliers who can provide us migration data and we do a risk assessment and validate our final products with migration testing at least on a random basis, I believe that we have done due diligence. It will be  an exorbitantly costly exercise if we were to check each and every item we manufacture every year.

Auditors have always looked at food contact regulatory statements and migration test reports from our raw material suppliers and the few migration tests that we have done and seem to accept the information provided to them.

Regards

Lakmal

Hi Kristina,

Not a procedure as such Its a risk assessment.

What is the likelihood of a reaction? is the product put in the oven, microwave (I guess not) This could cause a reaction between the components.

Do the suppliers state ppm of migrating components/ heavy metals?

if so you can add the ppm of the ingredient /components and make sure they do not total above the threshold.

This may not be possible as some may be reported and not detected or below detection level.

If the detection level is 0.002 for example, in a worst case you could assume all components could be 0.002 (just below actually) if there are 3 components that would =0.006 ask is this now above the threshold?

Just applying logic. 

Hi Sharon,

Thks for above.

Not my area, just curious. Is there not a specific definition of how to measure the compliance with "threshold"  limit ?

Interestingly enough, I was just informed this morning that we have a customer that would like us to print and / or coat on the inside of a newly designed box! This is where migration testing will have to be done pretty much continuously through every run, it will have to be a flexo print / coat and we will likely have to have a new coating developed. I realize the customer is always right but, the customer ISN'T always right or knowledgeable. I have addressed this in the past and explained the need for the extra lab as well as internal testing and the issue of migration they hadn't considered.

Hi Sharon,

 

Thks for above.

Not my area, just curious. Is there not a specific definition of how to measure the compliance with "threshold"  limit ?

Hi Charles,

This is an except form EU 10/2011:

• As migration testing is complex, costly and time consuming it should be admissible that compliance can be demonstrated also by calculations, including modelling, other analysis, and scientific evidence or reasoning if these render results which are at least as severe as the migration testing. Test results should be regarded as valid as long as formulations and processing conditions remain constant as part of a quality assurance system.

 

Hi Charles,

This is an except form EU 10/2011:

• As migration testing is complex, costly and time consuming it should be admissible that compliance can be demonstrated also by calculations, including modelling, other analysis, and scientific evidence or reasoning if these render results which are at least as severe as the migration testing. Test results should be regarded as valid as long as formulations and processing conditions remain constant as part of a quality assurance system.

 

hi Beautiophile,

Thks for above. I interpret as meaning it is necessary to perform some experiment to demonstrate  that (2+2+2) is not less than 6. Hmm.

Hi Kristina,

Not a procedure as such Its a risk assessment.

What is the likelihood of a reaction? is the product put in the oven, microwave (I guess not) This could cause a reaction between the components.

Do the suppliers state ppm of migrating components/ heavy metals?

if so you can add the ppm of the ingredient /components and make sure they do not total above the threshold.

This may not be possible as some may be reported and not detected or below detection level.

If the detection level is 0.002 for example, in a worst case you could assume all components could be 0.002 (just below actually) if there are 3 components that would =0.006 ask is this now above the threshold?

Just applying logic.

 

 

Hi Sharon,

I'm having a bit of bother obtaining migration information from our board supplier, am I right in thinking it is something the our supplier can request from the manufacturer.

Hi Kristina,

We buy board from agents, they get the information from the mills at our request. They are often from a company/test facility  call ISEGA. So yes your supplier should be able to get it for you from the mill/ manufacturer. 

Hi Kristina,

We buy board from agents, they get the information from the mills at our request. They are often from a company/test facility  call ISEGA. So yes your supplier should be able to get it for you from the mill/ manufacturer. 

Hi Sharon,

Could you share an example of such information?

Kris

Hi,

Please see an example attached.

Hi Kristina,

I think most of the above replies are for plastics not sleeves & Cartons of Folding Box Board.

Reg (EU) 10/2011 is for plastic.

We do printed sleeves and cartons. We have taken information from all the suppliers (board, ink, varnish glue, foiling, window patching etc.)  to ensure the individual components are safe with regards to migration etc. We have done a risk assessment about the effects of combining the components with their individual contribution (will they react together? will they cumulate to be greater than allowed) and based on that we do not do migration testing. We have composed a declaration in line with the BRC clause 3.4.3. based on the information form the suppliers who have usually done migration on their components.

Hi Sharon,

Could you share a copy of your declaration? It looks like I'm going to have to carry out a risk assessment too.

Kris

Hi Kris,

please see attached. This information was gleaned form the info given to us by our suppliers.

Hi Kris,

please see attached. This information was gleaned form the info given to us by our suppliers.

Thank you very much Sharon.