5 replies to this topic

[Rassmutten]

I am fairly new to the flexible packaging industry and in doing research I discovered that a lot of states  are requiring testing on packaging for heavy metals. What I find strange is that nobody I have spoken to seems to be aware of this. My company is in converting so we have not done it and the company we purchase from does not send us results of any testing just a LOG. The laws say a LOG is not good enough and on top of that our company should be doing random testing as well. I'm new to the industry but nobody here knew about any of these state laws so I am trying to get us up to speed. Does anybody have any experience with doing this testing? if so, how often and do you have an SOP or policy you are willing to share? I feel like I need to know more but packaging regulations are scattered all over the place and it makes me crazy.

 

Thank you in advance.

[NajeebRehman]

Heavy metal testing for packaging mainly targets lead, cadmium, mercury, and hexavalent chromium, with most global regulations (EU, US TPCH) setting a combined limit of 100 ppm. Testing is usually done through ICP-MS, ICP-OES, or AAS, along with migration studies for food-contact materials. Standards vary slightly by country—China limits migration to 1.0 mg/L, while India sets strict migration limits for lead and cadmium. In practice, companies ensure compliance through supplier certifications, periodic testing, and use of safe inks, coatings, and adhesives, with proper documentation for food safety audits.

[Raji@1122]

Heavy Metal Testing in Packaging
Packaging for food/nutraceuticals must meet strict limits for lead, cadmium, mercury, and hexavalent chromium (≤100 ppm total under EU 94/62/EC and US TPCH). Food-contact regulations (EU 1935/2004, FSSAI, FDA) require migration testing into food simulants to ensure no harmful transfer. Testing covers substrates, inks, adhesives, recycled layers, typically via ICP-MS/ICP-OES. Accredited lab reports and compliance certificates are often required by buyers. Regular testing is vital when materials, inks, or suppliers change.

For tailored support on packaging compliance and product development, Click here..

[Rassmutten]

Thank you so much for the words of wisdom. My suppliers have provided the documentation, and it is within range. What my company has never done is ask for test results from our suppliers or conduct testing on our own. Any advice on how often we should send out samples for testing? Does anyone have a generic copy of a policy they would be willing to share? When I saw what the fines were from the states I went into a full-blown panic, and I want to get this situation rectified as soon as possible. I might add that no Food Safety Auditor has ever asked for this information.

[jfrey123]

Which laws are you referring to that state LoG's are insufficient?  I'm just curious and want to evaluate this for my company as well.

 

Arguably, if your supplier can provide a CoA showing the levels are good, then you *shouldn't* have to test because they already have.  My company has close to 100 different types of food contact packaging, and being told we have to have each one tested would be a nightmare atop a huge expense.  I'd argue if you can prove your manufacturers are controlling this hazard in their programs, then spot checking a few items at 6 month intervals is likely a fine step towards your supplier monitoring practices.

[Rassmutten]

I have done additional research and spoken with Toxins in Packaging Clearinghouse. The understanding that I have now is that we are responsible for knowing what is in our product. That is obvious. We should not be relying on an LOG from a supplier. I do not see that there is a law that says we can't rely on them, but best practice is not to. This falls under product fraud and food defense. My perspective new customer wants proof of heavy metals levels beyond LOG.  Not all states have laws, but your product maybe sold in a state that does have the law. Apparently state agencies have started going out and randomly test product on shelves in the last few years. Some states have incredibly high fines. I have not yet found anything that says we HAVE to test however we are liable if the levels are higher than allowed therefore it is best practice and good insurance against fines or recall. I have been told that recalls have resulted from the state level inspections. At this point I am unable to find anything that tells me how often to test product that has not had a formula change. To get us up to speed I will test all of our current products. I am told the test cost about 100.  per test. Testing will show diligence on our side. Periodic random testing is still best practice but I'm not sure how often to do that.  The Toxins in Packaging Clearinghouse has a wealth of information. Please let me know if I am on the right track.