Food safety and compliance testing for plastics in the UK/EU
Council Regulation 1935/2004 EC and Commission Regulation 10/2011 (EU)
In the UK and EU, all plastic products intended to come into contact with food (including kitchen utensils, sports bottles, food boxes, food bags, lunch boxes, feeding bottles and lunch bags) must be proven not to transfer materials into the food that will affect its taste or quality.
All food contact plastics must therefore undergo rigorous testing at laboratories – such as ours here at Northern Testhouse in Leicester – to ensure their suitability and consumer safety.
The UK’s general standards for food safety are similar to those of EU member states, which are governed by the European Parliament and Council Regulation 1935/2004 EC. For plastics specifically, compliance with this Regulation is defined by Commission Regulation (EU) 10/2011 on plastic materials and articles intended to come into contact with food.
What are the key provisions of Commission Regulation (EU) 10/2011 on food contact plastics?
Commission Regulation (EU) 10/2011 outlines restrictions on the composition of plastics that are intended to, or could reasonably be expected to, come into contact with foods. It designates specific and overall migration limits and provides specific guidance for plastic multi-layer, and multi-material multi-layer, materials and articles.
It sets restrictions as to which kinds of plastics can be used in products that come into contact with food, and provides methodologies for plastic product safety testing that we at Northern Testhouse follow to ensure the safety and compliance of your plastic products.
What is a plastic product in the sense of Commission Regulation (EU) 10/2011?
Under the terms of the Regulation, a plastic product is defined as:
A material or article (or parts thereof) consisting exclusively of plastics
Plastic multi-layer materials and articles held together by adhesives or by other means
Plastic materials and articles that are printed and/or covered by a coating
Plastic layers or plastic coatings forming gaskets in caps and closures that compose a set of two or more layers of different types of materials
Plastic layers in multi-material multi-layer materials and articles.
Do I have to prepare a declaration of compliance (DoC) under Commission Regulation (EU) 10/2011?
Yes, Commission Regulation (EU) 10/2011 states that a written declaration of compliance must be produced for plastic materials, articles and products at all stages of production and marketing from the intermediate stages of their manufacturing, as well as for the substances intended for the manufacturing of those materials and articles.
Northern Testhouse can help you with preparing this, as well as provide documentation that details the conditions and results of testing, our calculations, including modelling, other analysis, and evidence on the safety or reasoning demonstrating compliance.
What tests does Northern Testhouse carry out to ensure compliance with Commission Regulation (EU) 10/2011?
We expose your product to a range of food simulants at high temperatures and over long periods of time to verify its compliance with overall standards such as migration, specific metal release and specific monomer release. The rules regarding the testing are specified in Annex V of Commission Regulation (EU) 10/2011.
What kinds of migration are assessed under Commission Regulation (EU) 10/2011?
Overall migration
Overall migration pertains to any materials that can migrate from the plastic or food contact material into foods. Whilst identification of the migrating substances is not required, results can be used for assessing non-volatile specific monomers such as BPA, PAA etc.
EN1186 Parts 1, 3, 9 & 14 are established standards for overall migration testing. Part 1 specifies test conditions and appropriate simulants. This supports Annex II Table 2 conditions of (EU)2020/1245.
Specific metal release
Specific metals release is the determination of metals specified in Annex 11 Table 1 of (EU) 2020/1245 that could migrate into food stuffs. Unlike overall migration, as there are no assigned simulants, EN13130 Part1 forms the basis of selecting simulants and conditions.
Specific monomer release
Specific monomer release such as BPA, PAA, Formaldehyde, Phthalates etc. applies to the type of plastic. As there are no assigned simulants for specific monomer release testing, EN13130 Part1 forms the basis of selecting simulants and conditions
At the Northern Testhouse, we perform tests to support commission regulations (EU)2020/1245.
After an initial review, we will test your product and assess its conformity for the relevant safety test and certification needed to import, distribute, or sell it.
If your product passes, you will receive:
The product test reports
The UK/EU certification you need
Should your product fail, we will advise you on how to make it safe.