EU Food Contact Materials: Migration Testing, NIAS, BPA & PFAS Compliance in 2026
Food packaging does more than protect products—it must also help prevent harmful substances from transferring into food. As regulatory requirements evolve across the European Union, manufacturers, packaging converters, food brands, and exporters need to assess the chemical safety of materials intended to come into contact with food.
From plastic containers and multilayer packaging to coatings, printing inks, adhesives, and paper-based materials, migration testing is a critical tool for evaluating food contact safety and supporting regulatory compliance.
In 2026, businesses should pay particular attention to overall and specific migration, non-intentionally added substances (NIAS), bisphenol A (BPA), and per- and polyfluoroalkyl substances (PFAS).
1. EU Regulatory Developments to Watch in 2026
Through Draft Notification G.S.R. 745(E), dated 19 August 2026, the Ministry of Health & Family Welfare has proposed adding four additional drugs to Schedule H1 of the Drugs Rules, 1945:
A. PFAS restrictions in food-contact packaging
The EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) began applying on 12 August 2026, including restrictions on PFAS in food-contact packaging above specified limits. These requirements are particularly relevant to grease-resistant paper, takeaway packaging, food wrappers, and other packaging designed to resist oil and moisture.
What businesses should assess:
- Total fluorine screening
- Targeted PFAS analysis, where required
- Further investigation of samples exceeding screening thresholds
- Supplier declarations and supporting compliance documentation
The European Commission’s implementation guidance describes a stepwise approach involving total fluorine screening and additional analysis where necessary. Testing should be selected according to the applicable limits and intended packaging use.
B. Bisphenol A (BPA): tighter controls
Commission Regulation (EU) 2024/3190 introduced a prohibition on the use of BPA in specified food-contact materials, subject to defined derogations and transitional provisions. Commission Regulation (EU) 2026/250 subsequently corrected aspects of those provisions, including certain transition dates.
BPA-related compliance assessments may involve:
- Residual BPA determination
- Specific migration testing
- Assessment of other regulated hazardous bisphenols and derivatives
- Verification of applicable transitional provisions
- Review of supplier declarations and technical documentation
Manufacturers should assess the exact material, intended use, and applicable exemption or transition before determining the required testing scope.
C. Migration testing: demonstrating chemical safety
Under the EU framework, food-contact materials must not transfer constituents into food in quantities that could endanger human health, cause unacceptable changes in food composition, or adversely affect its organoleptic properties.
For plastics, Commission Regulation (EU) No 10/2011 establishes overall migration and specific migration requirements. The overall migration limit is generally 10 mg/dm² of contact surface or 60 mg/kg of food, subject to the applicable conditions and exceptions.
Testing may include:
- Overall Migration (OML): assesses total substances migrating under prescribed conditions.
- Specific Migration (SML): measures individual substances subject to specific limits.
- Food simulant testing: uses appropriate simulants to represent intended food types.
- Time–temperature conditions: reflects foreseeable contact, storage, and use conditions.
The test plan should be based on the material composition, food type, contact duration, temperature and intended conditions of use.
D. NIAS: non-intentionally added substances
NIAS can arise from impurities in raw materials, side reactions during manufacturing, degradation, or interactions between packaging components.
Examples include reaction by-products, degradation products, and contaminants originating from recycled materials.
Although NIAS are not intentionally added, their presence may still require evaluation to demonstrate the safety of the finished material. EFSA identifies migration data and toxicological information as important inputs when evaluating potential risks from chemicals transferred from food-contact materials.
Recommended assessment approach:
- Identify potential NIAS based on formulation and manufacturing processes.
- Use suitable screening techniques such as GC-MS and LC-MS/MS.
- Characterize and identify relevant detected compounds.
- Evaluate exposure and toxicological relevance where required.
- Document the risk assessment and supporting evidence.
2. Key Testing Parameters at a Glance
| Testing area | Key analytical focus |
| Overall migration | Total migration into food simulants |
| Specific migration | Regulated substances and applicable SMLs |
| BPA and bisphenols | Residual content and/or migration |
| PFAS | Total fluorine screening and targeted PFAS |
| NIAS | Screening, identification and risk assessment |
| Metals | Relevant elemental migration |
| Volatile and semi-volatile compounds | GC-MS-based screening where suitable |
The applicable methods and parameters depend on the packaging material, intended use, substance-specific legislation, and regulatory limits.
3. Which Industries Should Pay Attention?
Plastic packaging manufacturers
Migration testing, regulated substance verification, and supporting documentation for plastic food-contact articles.
Paper and board packaging
PFAS-related assessments, chemical screening, and suitability for intended food-contact applications.
Metal cans, coatings and closures
BPA-related compliance, coating constituents, and relevant migration assessments.
Food brands and exporters
Supplier verification, packaging compliance evidence, and risk-based assessment of packaging used for EU-bound products.
4. How Eureka Analytical Services Supports You
Eureka supports food and packaging businesses with analytical testing to help evaluate product quality and applicable regulatory requirements.
Our relevant testing support includes:
- Migration testing for applicable food-contact materials
- Heavy metal and elemental analysis
- Chemical screening using suitable analytical techniques
- Targeted contaminant analysis, subject to validated scope
- Analytical reports to support compliance assessments
Testing scope and method availability should be confirmed for the specific material, analytes and regulatory requirement
5. Practical Compliance Checklist for 2026
Food businesses and packaging suppliers should:
- Review packaging composition and intended use.
- Identify applicable EU requirements for each material.
- Assess BPA and PFAS risks based on material type and use.
- Establish an appropriate migration and NIAS testing strategy.
- Obtain supplier declarations and supporting technical documentation.
- Review test reports against the applicable legal limits.
- Reassess packaging when formulations, suppliers, or manufacturing processes change.
Conclusion: Test Beyond the Visible
Food-contact compliance is no longer just about the packaging material itself. It also requires understanding what may migrate into food, identifying potentially hazardous substances, and maintaining appropriate evidence of safety.
We help businesses make informed decisions through reliable analytical testing and quality-focused support.
Protect packaging integrity. Strengthen compliance. Build confidence in every food-contact material.
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