Trace Metals Testing for Food Contact Materials

The migration of metal-containing substances from food contact materials may present a health risk if not controlled or properly understood. Testing and analysis that is compliant with the relevant regional or national food contact guidelines are necessary to ensure safety. Article three of Framework Regulation 1935/2004, on materials and articles intended to come into contact with food, states, "food contact materials must not transfer their constituents to food in quantities which could endanger human health". Analysis of inorganic compounds in food contact materials (FCM) or analysis of the migration of these substances from FCM into foodstuffs is essential to mitigate risk and ensure materials comply with relevant national and regional food contact laws and guidelines. There are several possible sources of exposure to metallic-containing substances including compounding, printing, food processing, filling, and recycling. Metal ions or metal-containing substances may also be present as non-intentionally added substances (NIAS). Analytical testing for metals and programs which identify inorganic NIAS is crucial to the safety of the food contact article or material.  

Depending on the material of the FCM, the relevant guidance documents must be adhered to. For example, in Europe, the metals and alloys technical guide is a collaborative work of the European Committee for Food Contact Materials and Articles (CD-P-MCA), the steering committee of the European Directorate for the Quality of Medicines & HealthCare (EDQM) which addresses emerging risks to human health arising from the use of food contact materials and articles. The revised second edition includes the Council of Europe Resolution CM/Res(2020)9 on the safety and quality of metallic materials and articles for contact with food, lays out the general principles and recommendations for testing the migration of metals and inorganic compounds. This current edition highlights chemical elements that constitute metallic FCM or may be present in certain alloys and sets out specific release limits (SRLs) for multiple elements such as chromium, manganese, thallium, and a new section on zirconium.

In a recent amendment to Regulation EU 10/2011 (Regulation (EU) 2020/1245), migration limits and specified restrictions for a range of metal substances were included in Annex II. The amendment states that these substances shall not be released from plastic materials and articles in quantities exceeding specific migration limits (SML). The following substances have SML: aluminium, ammonium, antimony, arsenic, barium, cadmium, calcium, chromium, cobalt, copper, europium, gadolinium, iron, lanthanum, lead, lithium, magnesium, manganese, mercury, nickel, potassium, sodium, terbium, and zinc. The latest amendment to Regulation EU 10/2011 (Regulation (EU) 2024/3190) maintains these details on inorganic substances in plastic food packaging without any changes.

The German BfR guidelines are frequently utilised in Europe to perform testing on those FCM without harmonised legislation. For example, German BfR XXXVI on paper and board for food contact is widely used to show these FCM do not contravene Article three of Framework Regulation 1935/2004. This chapter of the German BfR contains SML for several metals, such as aluminium and lead, and includes specific test methods for the analysis. 

Testing to Mitigate Risks Associated with Migration of Metals into Food
Reliable quantification of metal elements that could migrate from FCM is critical to ensuring the safety of these products. Our experts provide efficient laboratory analysis using robust, industry-established migration testing, using sensitive inductively coupled plasma (ICP) detection to analyse inorganic elements. Not only can we analyse for elements to ensure compliance with SML stated in specific legislation or guidelines, but we can also conduct analysis for inorganic NIAS substances using semi-quantitative screening. In addition to analysing migration extracts for inorganic elements, our experts are highly experienced in suitable sample preparation techniques including acid and microwave digestion. We use ICP technologies with optical emission spectroscopy (ICP-OES) and mass spectrometry (ICP-MS) detection, which are key to delivering robust results that can help manufacturers demonstrate regulatory compliance, select suitable raw materials, and reduce contamination risks. Many of our inorganic analysis and quantification methods are UKAS accredited to ISO 17025. For trace levels (sub-ppb) of mercury, we analyse samples using our Flow injection Mercury system (FIMS).

Heavy Metals Testing for Food Contact Materials
Using our end-to-end services, our experts can support you in understanding what analysis is required, how it should be performed in line with guidance or legislation, and how to interpret the final data to show compliance with food contact regulations and guidance. We can perform migration studies and quantification of metals which are not authorised to be used in the manufacture of plastic FCMs including arsenic, cadmium, chromium, lead, and mercury. While heavy metals are typically controlled during the manufacturing stages of plastic materials, these metals can be introduced as contaminants throughout the supply chain and be present in final plastic FCMs, posing health risks to consumers. Annex II of the Regulation (EU) 10/2011 has clearly defined migration limits for metals and inorganic elements, based on the opinions of the EFSA Authority, which allows uniform analytical verification of compliance.

Your Food Packaging Testing Partner
Bringing quality, safety, and sustainability to life, we apply our food contact materials testing  expertise to support your food contact packaging development, compliance from early-stage R&D to recycling and beyond. Our portfolio of expertise includes migration testing, analysis for substances of concern including primary aromatic amines, per- and poly-fluoroalkyl substances (PFAS), bisphenol A (BPA), bisphenol A diglycidyl ether (and related compounds), the release of microplastics, MOSH / MOAH and phthalates. Coupled with regulatory assurance, our innovation-led, end-to-end Total Quality Assurance capabilities for packaging testing help organisations operate safely, effectively and with complete peace of mind in an increasingly complex, fast-changing world.