EU Food Contact Materials: Migration Testing, NIAS, BPA & PFAS Compliance in 2026

Introduction

Food packaging is an essential part of the modern food supply chain, but the packaging itself must also be safe.

When food comes into contact with plastic, paper and board, metal, glass, coatings, adhesives, printing inks or other materials, chemical substances can potentially transfer from the food contact material (FCM) into the food.

This transfer is known as migration.

The European Union has established a comprehensive regulatory framework to control the safety of food contact materials. In 2026, compliance has become particularly important because of developments concerning overall and specific migration, non-intentionally added substances (NIAS), bisphenol A (BPA), other hazardous bisphenols and PFAS in food-contact packaging.

The EU framework is built around the principle that food contact materials must not release substances at levels that could endanger human health or cause unacceptable changes to food composition, taste or odour.

For manufacturers and exporters supplying packaging or packaged food to Europe, migration testing is therefore not simply a quality check. It is an important component of demonstrating regulatory compliance.

What Are Food Contact Materials?

Food Contact Materials (FCMs) are materials and articles intended to come into contact with food during manufacturing, processing, packaging, storage, transportation, preparation or serving.

Examples include:

- Plastic packaging and containers
- Multilayer films and laminates
- Paper and paperboard
- Glass
- Metals and alloys
- Food-contact coatings and varnishes
- Adhesives
- Printing inks
- Rubber and elastomers
- Kitchenware and tableware
- Food-processing equipment
- Recycled materials used in food-contact applications

The EU framework applies to FCMs throughout their intended use, not only to finished retail packaging.

EU Regulatory Framework for Food Contact Materials

The main EU framework consists of several layers of legislation.

Regulation (EC) No 1935/2004

This is the principal Framework Regulation for Food Contact Materials.

It establishes the general safety principle that FCMs must be sufficiently inert so that they do not:

Transfer constituents into food at levels that could endanger human health
Cause an unacceptable change in food composition
Cause deterioration of organoleptic characteristics such as taste and odour

It also establishes requirements relating to traceability, labelling and supporting compliance documentation.

Regulation (EC) No 2023/2006

This establishes Good Manufacturing Practice (GMP) requirements for materials and articles intended to come into contact with food.

GMP controls are important because compliance depends not only on the final material, but also on controlled manufacturing processes.

Regulation (EU) No 10/2011

This is the principal EU legislation specifically governing plastic materials and articles intended to come into contact with food.

It includes the Union List of authorised substances and establishes requirements concerning:

Specific migration
Overall migration
Food simulants
Test conditions
Compliance assessment
Declaration of Compliance
Supporting documentation

The regulation has been amended several times and should always be assessed using its current consolidated version.

What Is Migration Testing?

Migration testing evaluates whether chemical substances can transfer from a food contact material into food or an appropriate food simulant under defined conditions.

The test conditions are designed to represent, or in certain circumstances conservatively simulate, the intended use of the material. Migration testing can involve:

Food-contact material → Food simulant → Controlled contact conditions → Extraction/analysis → Compliance assessment

The test design depends on factors such as:

Material composition
Food type
Contact time
Contact temperature
Intended use
Single-use or repeated-use application
Storage conditions
Heating conditions
Surface-to-volume ratio

For plastic FCMs, Regulation (EU) No 10/2011 specifies the relevant framework for migration testing and assessment.

Overall Migration vs Specific Migration

Understanding the difference between these two concepts is essential.

Overall Migration

Overall Migration Limit (OML) evaluates the total amount of non-volatile substances that migrate from a plastic material into the food simulant under prescribed test conditions.

It provides an overall measure of migration rather than identifying individual substances.

Specific Migration

Specific Migration Limit (SML) applies to an individual substance or group of substances.

A substance may have a specific migration limit based on its toxicological assessment and intended use.

Therefore, a material can require both:

Overall migration testing
Specific migration testing

depending on its composition and regulatory requirements.

The current Regulation (EU) No 10/2011 also establishes detailed rules for expressing migration results, applying surface-to-volume ratios and assessing compliance.

Why Food Simulants Matter

Testing directly with every type of food is not always practical.

Food simulants are therefore used to represent different food-contact conditions.

The selection of the appropriate simulant and test condition depends on the intended food contact and use conditions specified under the applicable legislation.

For example, a packaging material intended for fatty food may require a different testing approach from one intended for aqueous or acidic foods. The contact time and temperature are equally important.

A packaging material intended for:

Long-term room-temperature storage
Refrigerated storage
Hot filling
Microwave heating
Oven use

may require substantially different compliance testing.

Therefore, migration testing should always be based on the actual or reasonably foreseeable intended use of the finished article.

NIAS: The Growing Challenge in FCM Compliance

One of the most important developments in food contact safety is the increasing focus on Non-Intentionally Added Substances (NIAS).

NIAS are substances that are not deliberately added to the material as ingredients but may occur as a result of:

Manufacturing processes
Chemical reactions
Degradation
Impurities
Interaction between components
Recycling processes
Storage or ageing
Reaction between substances within multilayer structures

Examples may include degradation products, reaction products, impurities and other substances generated during manufacturing or use.

Why NIAS Testing Is Important

A traditional compliance assessment may begin with the known composition of a packaging material.

However, the finished article can contain substances that are not obvious from the intentionally added formulation.

This creates an important distinction:

Known formulation ≠ complete chemical profile of the finished FCM

For this reason, NIAS assessment increasingly involves a combination of:

Supplier information
Raw material composition
Manufacturing-process information
Analytical screening
Substance identification
Exposure assessment
Toxicological assessment where necessary

EFSA’s work on food contact materials has also highlighted the need for greater focus on finished materials and NIAS generated through FCM manufacturing, particularly as part of evolving risk-assessment approaches.

NIAS Screening: What Does It Involve?

NIAS screening is generally more exploratory than conventional targeted migration testing.

Depending on the material and risk assessment, analytical screening may involve techniques such as:

GC-MS
LC-MS/MS
High-resolution mass spectrometry
Targeted and non-targeted screening
Extractable and leachable profiling

The objective is to identify potentially migrating substances that may not be included in a conventional targeted test list.

However, NIAS screening should not automatically be treated as a simple pass/fail test.

A detected substance may require further evaluation based on:

Identity
Concentration
Migration potential
Intended food contact
Consumer exposure
Toxicological relevance
Applicable regulatory requirements

This makes NIAS assessment an important intersection between analytical chemistry and chemical risk assessment.

BPA Compliance: A Major 2026 Focus

Bisphenol A (BPA) has become a major regulatory focus within the EU food contact framework.

BPA has historically been used in applications including:

Polycarbonate plastics
Epoxy resins
Food-contact coatings
Can coatings
Printing inks
Adhesives and other components of food-contact articles

The European Commission adopted Regulation (EU) 2024/3190 concerning BPA and other hazardous bisphenols and bisphenol derivatives used in certain food contact materials and articles.

The regulation significantly restricts the use of BPA in food contact materials, subject to specified derogations and transitional provisions.

The regulation was also corrected by Commission Regulation (EU) 2026/250, which should be considered when assessing the current 2026 legal position.

BPA Testing and Compliance Verification

BPA compliance can involve assessment of:

Residual BPA
Migration of BPA
Applicable hazardous bisphenols
Bisphenol derivatives
Material composition
Intended application
Applicable transitional provisions

The 2024 BPA regulation contains specific requirements for verification methods.

For verification of residual BPA and other relevant substances, the regulation establishes a 1 µg/kg detection-limit requirement unless a different limit applies, and specifies that an EURL-recommended method should be used where available.

This makes method sensitivity particularly important when demonstrating compliance.

PFAS in Food-Contact Packaging: A Key 2026 Development

PFAS are a broad group of highly persistent fluorinated substances.

They have historically been used in applications requiring properties such as:

Oil resistance
Grease resistance
Water resistance
Chemical resistance

PFAS can therefore be relevant to certain food-contact packaging applications, particularly paper and board treatments.

The EU regulatory landscape has moved significantly in 2026.

Under the Packaging and Packaging Waste Regulation (EU) 2025/40, specific restrictions on PFAS in food-contact packaging apply from 12 August 2026.

EU PFAS Limits for Food-Contact Packaging

From 12 August 2026, food-contact packaging must not be placed on the EU market if it contains PFAS at or above the specified thresholds, subject to the regulation’s scope and interaction with other EU legislation.

The limits include:

PFAS assessment	Limit
Any PFAS by targeted analysis, excluding polymeric PFAS	25 ppb
Sum of targeted PFAS, with precursor degradation where applicable, excluding polymeric PFAS	250 ppb
PFAS including polymeric PFAS	50 ppm

These thresholds apply to food-contact packaging under the Packaging and Packaging Waste Regulation.

This is an important 2026 compliance consideration for packaging manufacturers and exporters supplying the EU market.

How Should PFAS in Food-Contact Packaging Be Tested?

A major practical issue is that there is currently no single harmonised EU analytical method for PFAS in food-contact packaging.

The European Commission’s 2026 guidance recommends a stepwise approach for enforcement.

Step 1 – Total Fluorine standardisation work is needed.

Total fluorine can be used as an initial screening measurement.

If total fluorine is below 50 mg/kg, the packaging may be considered compliant under the Commission’s recommended approach.

Step 2 – Determine Organic Fluorine

If total fluorine exceeds 50 mg/kg, further testing can help determine whether the fluorine is organic and potentially associated with PFAS.

Methods such as pyrolysis-GC/MS may be used for this purpose.

Step 3 – PFAS / Precursor Assessment

Where required, direct TOP (Total Oxidizable Precursor) analysis can be used to assess compliance with the applicable PFAS thresholds.

The Commission’s 2026 guidance specifically describes this stepwise approach in the context of enforcing the PFAS requirements from 12 August 2026.

Why PFAS Compliance Requires More Than One Test

A single targeted PFAS panel may not provide a complete picture of fluorinated chemistry in a packaging material.

For this reason, a risk-based testing strategy may combine:

Total Fluorine → Organic Fluorine → Targeted PFAS → Precursor assessment

The appropriate approach depends on the packaging material, application, regulatory requirement and analytical objective.

For manufacturers, this also means that supplier declarations alone may not always be sufficient as the only compliance evidence, particularly where PFAS restrictions and market surveillance requirements apply.

Declaration of Compliance and Supporting Documentation

Testing is only one component of FCM compliance.

For plastic food contact materials, Regulation (EU) No 10/2011 requires a written Declaration of Compliance (DoC) at relevant stages of the supply chain.

Supporting documentation should be available to demonstrate compliance.

This can include:

Composition information
Test conditions
Migration results
Calculations or modelling
Analytical data
Method information
Safety assessment
Supporting supplier documentation

The DoC should also be updated when substantial changes in composition or manufacturing affect migration, or when new scientific information becomes relevant.

FCM Compliance Is More Than Migration Testing

A complete compliance assessment should consider the entire product and its intended use.

Depending on the material, application and market, the assessment may include:

Chemical composition

Review substances intentionally added during manufacturing.

Migration

Evaluate overall and/or specific migration under applicable conditions.

NIAS

Screen for substances generated unintentionally during manufacturing, storage or use.

BPA and other bisphenols

Assess applicable restrictions and migration or residual levels.

PFAS

Evaluate applicable PFAS restrictions for food-contact packaging.

Sensory characteristics

Consider potential impacts on taste, odour and food quality.

GMP

Evaluate manufacturing controls under the applicable GMP framework.

Documentation

Maintain appropriate DoC and supporting compliance records.

FCM Testing for Different Packaging Materials

The regulatory approach depends strongly on the material.

Plastic

Plastic FCMs are subject to the detailed requirements of Regulation (EU) No 10/2011, including authorised substances, migration testing and compliance documentation.

Paper and Board

Paper and board may require assessment under applicable EU Member State requirements and other relevant legislation, because there is not a single comprehensive harmonised EU measure equivalent to the plastics regulation.

PFAS restrictions are particularly relevant for food-contact paper and board where fluorinated treatments may have been used.

Metal

Metal packaging may require assessment of coatings, varnishes, additives, metals and potential migrants.

BPA-related restrictions can be particularly important where epoxy-based coatings are involved.

Glass and Ceramics

Assessment may include migration of relevant elements and substances depending on the material and applicable specific legislation.

Multilayer Packaging

Multilayer structures require careful consideration of:

Individual layers
Adhesives
Printing inks
Coatings
Functional barriers
NIAS
Migration through the overall structure

Therefore, testing only the individual raw materials may not always represent the behaviour of the finished packaging article.

What Should Exporters to the EU Do in 2026?

Companies exporting food packaging or packaged food to the EU should review their FCM compliance strategy rather than relying solely on historical test reports.

A practical review should include:

1. Identify the material

Determine whether the packaging is plastic, paper/board, metal, glass, ceramic, multilayer or another material.

2. Define the intended food contact

Identify the food type, contact duration, temperature and intended use.

3. Review regulatory requirements

Identify applicable EU and Member State legislation.

4. Review formulation

Obtain updated information on intentionally added substances and relevant suppliers.

5. Evaluate NIAS

Consider whether manufacturing, printing, coating, adhesives, recycling or degradation could generate additional substances.

6. Assess migration

Conduct appropriate overall and/or specific migration testing.

7. Address BPA and PFAS

Review applicable restrictions and analytical requirements.

8. Prepare compliance documentation

Maintain the required Declaration of Compliance and supporting evidence.

9. Reassess after formulation changes

Any significant change in raw materials, formulation, processing or intended use should trigger a compliance review.

Common FCM Compliance Mistakes

Several recurring approaches can create compliance gaps.

Testing only the raw material

The finished article can behave differently from its individual components.

Using an outdated migration report

A historical report may not reflect the current legislation, formulation or intended use.

Treating NIAS as irrelevant because they were not intentionally added

NIAS can arise during manufacturing and may require risk assessment.

Relying only on a supplier declaration

Supplier documentation is valuable, but it should be evaluated together with the finished article’s intended use and appropriate analytical evidence.

Ignoring PFAS because the formulation does not intentionally contain PFAS

For certain packaging materials, screening may be appropriate to verify the absence or level of fluorinated substances.

Testing without considering actual use conditions

Migration testing must reflect the intended food, time and temperature conditions.

How Eureka Supports Food Contact Material Testing

Eureka can support manufacturers, packaging companies, food businesses and exporters with food contact material testing and chemical compliance assessment, subject to the applicable testing scope.

Depending on the material and regulatory requirement, support can include:

Overall migration testing
Specific migration testing
Food simulant-based migration studies
NIAS screening
BPA testing
Bisphenol-related analysis
PFAS screening and analysis
Chemical contaminant testing
Heavy metal and elemental analysis
Packaging material safety assessment
Compliance-oriented analytical testing

Eureka can also support businesses in developing a risk-based FCM testing strategy based on material composition, intended food contact, use conditions and destination-market requirements.

For export-oriented businesses, the objective is to generate analytical evidence that can support the broader FCM compliance and documentation framework, rather than treating individual test results in isolation.

Practical FCM Compliance Workflow

A structured approach can simplify food-contact packaging compliance:

Material & formulation review
↓
Intended food-contact conditions
↓
Applicable EU legislation
↓
Migration risk assessment
↓
OML / SML testing where applicable
↓
NIAS screening and assessment
↓
BPA / bisphenol evaluation
↓
PFAS assessment where applicable
↓
Result interpretation
↓
Declaration of Compliance & supporting documentation

Key Takeaways

EU Food Contact Material compliance in 2026 is becoming increasingly focused on the finished article, chemical migration and emerging substances of concern.

The key areas manufacturers and exporters should monitor include:

Overall and specific migration
Appropriate food simulants and test conditions
NIAS identification and risk assessment
BPA and other hazardous bisphenols
PFAS restrictions in food-contact packaging
GMP requirements
Declaration of Compliance
Supporting analytical and technical documentation

A particularly important 2026 development is the application of PFAS limits to food-contact packaging from 12 August 2026 under the Packaging and Packaging Waste Regulation.

At the same time, the EU’s evolving approach to BPA and other bisphenols means that manufacturers should ensure their compliance assessments reflect the current regulatory position, including the 2026 correction to Regulation (EU) 2024/3190.

For businesses exporting packaging or packaged food to Europe, migration testing, NIAS assessment and targeted substance testing should be considered as parts of one integrated FCM compliance strategy.

Frequently Asked Questions (FAQ)

1. What is food contact material migration testing?

Migration testing determines whether substances from a food contact material can transfer into food or food simulants under specified conditions of time and temperature.

2. What is the difference between OML and SML?

Overall Migration Limit (OML) evaluates the total amount of non-volatile substances migrating from a plastic FCM, while a Specific Migration Limit (SML) applies to an individual substance or specified group of substances.

3. What are NIAS in food packaging?

NIAS are Non-Intentionally Added Substances that can arise from impurities, degradation, reactions or manufacturing processes even though they were not deliberately added to the formulation.

4. Is NIAS testing mandatory for every food packaging material?

There is no single universal NIAS test applicable to every FCM. NIAS assessment should be based on the material, manufacturing process, intended use and applicable regulatory/risk-assessment requirements.

5. Is BPA banned in all food contact materials in the EU?

EU Regulation 2024/3190 significantly restricts BPA and certain other hazardous bisphenols in specified food contact materials, with limited authorised applications and transitional provisions. The applicable requirements should be assessed for the specific material and use.

6. Are PFAS restricted in EU food-contact packaging?

Yes. Under Regulation (EU) 2025/40, specific PFAS concentration limits for food-contact packaging apply from 12 August 2026, subject to the regulation’s scope and interaction with other EU legislation.

7. What PFAS limits apply to food-contact packaging?

The regulation specifies 25 ppb for any PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS with applicable precursor degradation, and 50 ppm for PFAS including polymeric PFAS, subject to the conditions of the regulation.

8. Can total fluorine be used for PFAS screening?

The European Commission’s 2026 guidance recommends total fluorine as the first step in a proposed stepwise enforcement approach. Where total fluorine exceeds 50 mg/kg, further analytical investigation can be performed.

9. Is a Declaration of Compliance required for plastic FCMs?

Yes. Regulation (EU) No 10/2011 requires a written Declaration of Compliance at relevant stages of the supply chain, supported by appropriate documentation.

10. How can Eureka support EU FCM compliance?

Eureka can support businesses with migration testing, NIAS screening, BPA/bisphenol analysis, PFAS assessment and other packaging-related chemical testing, subject to the applicable testing scope and regulatory requirements.

Official References

Regulation (EC) No 1935/2004 — Materials and Articles Intended to Come into Contact with Food
Commission Regulation (EC) No 2023/2006 — Good Manufacturing Practice for FCMs
Commission Regulation (EU) No 10/2011 — Plastic Materials and Articles Intended to Come into Contact with Food
Commission Regulation (EU) 2024/3190 — BPA and Other Hazardous Bisphenols in FCMs
Commission Regulation (EU) 2026/250 — Correction to Regulation (EU) 2024/3190
Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation
European Commission — Food Contact Materials
European Commission — 2026 Guidance on Regulation (EU) 2025/40 and PFAS in Food-Contact Packaging
European Food Safety Authority (EFSA) — Food Contact Materials
European Union Reference Laboratory for Food Contact Materials (EURL-FCM)
Applicable EU and Member State requirements for non-plastic food contact materials

Regulatory note: EU food-contact requirements can differ according to material, intended use, food type and Member State provisions. Manufacturers and exporters should verify the latest consolidated legislation and applicable guidance before making compliance decisions.