Food contact guide · Sources checked October 2026
Food contact migration testing requirements and test records
Food contact migration testing requirements for plastics in Great Britain are set by assimilated Regulation (EU) No 10/2011: plastics must not transfer substances above their specific migration limits or the overall migration limit of 10 mg per dm² of food contact surface, and compliance is tested in food or in food simulants under the conditions in Annex V. Migration test records are part of the supporting documentation a business must make available to the competent authorities on request.
Last updated .
Food contact migration testing requirements
The limits and how results are expressed
Regulation (EU) No 10/2011 as shown on legislation.gov.uk. Read the linked articles for exceptions.
On smaller screens, scroll the table sideways to see every column.
| Point | What the GB text says | Source |
|---|---|---|
| Specific migration limits | Plastics must not transfer constituents to food above the specific migration limits (SML) set in Annex I, expressed in mg of substance per kg of food | Regulation (EU) No 10/2011, Article 11 (legislation.gov.uk), checked October 2026 |
| No detectable migration | Where a substance must not migrate in detectable quantities, a detection limit of 0.01 mg/kg applies unless a specific one is set | Regulation (EU) No 10/2011, Article 11 (legislation.gov.uk), checked October 2026 |
| Overall migration limit | No more than 10 mg of total constituents per dm² of food contact surface; 60 mg per kg of food simulant for materials intended for infant and young children’s food | Regulation (EU) No 10/2011, Article 12 (legislation.gov.uk), checked October 2026 |
| Expressing results | Specific migration in mg/kg of food using the actual or foreseen surface area to volume ratio; a convention of 6 dm² per kg applies to small and very large containers, sheets and films, and items where the ratio cannot be estimated (not to infant food materials) | Regulation (EU) No 10/2011, Article 17 (legislation.gov.uk), checked October 2026 |
| Order of precedence | Results in food take priority over results in simulants, and simulant results over screening. A failed screening test must be confirmed by verification before non-compliance is concluded, and correction factors are applied before comparing with limits | Regulation (EU) No 10/2011, Article 18 (legislation.gov.uk), checked October 2026 |
Sources checked October 2026. Legislation and guidance change: open the linked source before relying on any row. This page is general information about the position in Great Britain, not legal or regulatory advice; your enforcement officer, your customers and your own technical advisers decide what applies to your materials.
Food contact testing documentation: simulants and conditions
Which simulant, and which test conditions
Annexes III and V, paraphrased. Assigning simulants to a particular food uses Table 2 of Annex III; read it for your food category.
On smaller screens, scroll the table sideways to see every column.
| Item | What the GB text says | Source |
|---|---|---|
| Food simulants | A: ethanol 10%; B: acetic acid 3%; C: ethanol 20%; D1: ethanol 50%; D2: vegetable oil; E: poly(2,6-diphenyl-p-phenylene oxide) for dry foods | Regulation (EU) No 10/2011, Annex III (legislation.gov.uk), checked October 2026 |
| Which simulant for which food | A, B and C for hydrophilic foods (B where pH is below 4.5; C for alcoholic foods up to 20% and some more lipophilic foods), D1 for alcoholic foods above 20% and oil-in-water emulsions, D2 for foods with free fat at the surface, E for dry foods | Regulation (EU) No 10/2011, Annex III (legislation.gov.uk), checked October 2026 |
| Specific migration conditions | Tested under the most extreme time and temperature foreseeable in actual use, mapped to set test times and temperatures (for example, contact above 20°C up to 40°C is tested at 40°C) | Regulation (EU) No 10/2011, Annex V, Chapter 2 (legislation.gov.uk), checked October 2026 |
| Repeated-use articles | The test is carried out three times on one sample with fresh simulant each time, and compliance is checked on the third test; migration should not rise from the first test to the third | Regulation (EU) No 10/2011, Annex V, Chapter 2 (legislation.gov.uk), checked October 2026 |
| Overall migration conditions | Standard tests OM0 to OM7, from 30 minutes at 40°C (short cold or ambient contact) through 10 days at 40°C (OM2, long-term storage at room temperature or below) to 2 hours at 175°C (OM7, high-temperature use with fatty foods) | Regulation (EU) No 10/2011, Annex V, Chapter 3 (legislation.gov.uk), checked October 2026 |
Sources checked October 2026. Legislation and guidance change: open the linked source before relying on any row. This page is general information about the position in Great Britain, not legal or regulatory advice; your enforcement officer, your customers and your own technical advisers decide what applies to your materials.
Migration test records
What a migration test record should show
A practical reading of Articles 16 to 18 and Annex V, not a legal test. The regulation asks for the conditions and results of testing; it does not set a report format.
Then check that the declaration’s use conditions match what was tested, as Annex IV point 8 requires them to be stated (declaration of compliance guide). For the rest of the evidence file, read food contact supporting documentation.
- The exact material or article tested, with the batch or production date and the declaration it supports.
- Whether the test was in food, in simulants or a screening method, and why that approach was chosen.
- The simulants used and why they match the intended foods.
- The test time and temperature, and the worst foreseeable use they cover.
- Single use or repeated use, and for repeated use, all three results.
- The surface area to volume ratio used, and whether the 6 dm² per kg convention applied.
- Results for overall migration and each substance with a specific limit, with correction factors and the limit next to each.
- Who carried out the test, the report date, and who reviewed it against the declaration.
Worked example (fictional)
Linking one test report to one declaration
A fictional product and test, for illustration only. It is not advice on how your material should be tested.
1
Define the use
Example Housewares Ltd, a fictional business, sells a reusable plastic lunch box for chilled and room-temperature foods, including oily foods, for up to a day.
2
Choose the test
Its laboratory proposes simulants for aqueous, acidic and fatty foods and a time and temperature that cover the worst foreseeable use, and records why.
3
Repeat the test
Because the box is reused, each test is run three times on the same sample with fresh simulant, and all three results are kept.
4
Compare and file
The quality lead checks each result against its limit after correction factors, files the report with the declaration it supports, and notes the conditions covered.
5
Know when to retest
When the supplier changes an additive, the team checks whether migration could change and, if so, retests before renewing the declaration.
Related guides
Read next
Test records sit inside a wider evidence file.
See supporting documentation, GMP and traceability records, the declaration of compliance guide and food contact compliance software compared, which includes two testing services.
Northern Ireland is different
The rows on this page describe the assimilated texts that apply in Great Britain. Some EU food contact rules apply in Northern Ireland under the Windsor Framework: for example, the FSA says Commission Regulation (EU) 2022/1616 on recycled plastic applies in Northern Ireland and not in Great Britain (FSA authorisation guidance, checked October 2026). If you supply Northern Ireland or the EU, read the EU text of Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011 on EUR-Lex, which may have been amended since 2020. In Scotland, read the Food Standards Scotland guidance.
Food contact tracking is not available yet
Soteriaa is building food contact declaration tracking; join the waitlist. It is not available yet, and it will not test materials, write or sign a declaration, or confirm that anything complies. Join the food contact waitlist to hear when it opens.
FAQ
Common questions
Is migration testing always required?
Regulation (EU) No 10/2011 says supporting documentation can contain testing, calculations including modelling, other analysis, or evidence on safety or reasoning. Which approach demonstrates compliance for a given material is a technical judgement for you and your advisers.
What is the difference between overall and specific migration?
Overall migration is the total amount of constituents that transfers, limited to 10 mg per dm² of contact surface. Specific migration is the amount of one substance, limited by the SML set for that substance in Annex I.
Which food simulant should I use?
Annex III assigns simulants by type of food, with a table by food category. A laboratory will usually propose them; record why each was chosen.
Does a test report replace the declaration of compliance?
No. The test report is supporting documentation. The declaration is a separate written statement that carries the use conditions and substance information down the supply chain.
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