Food contact testing: Legislation on Food-Contact Materials

Since the publication of the Regulation 10/2011, there have been some transitory dispositions that allow that the new legislation is being adapted progressively in some points.

These transitory dispositions make reference mainly to applied testing conditions, the legislation to which we have to make reference in the Declaration of Conformity of the articles, how to proceed with those who were already put in the market in the date of publication of the Regulation, etc.

2015 marks the year of the last transitory dispositions, which are these:

• Until the 31st December 2015 a declaration of conformity can be issued, which indicates the conformity with the Regulation 10/2011, if the supporting documents are based on tests made according to screening methods or verification methods (overall migration tests, specific migration and residual content) of the Regulation 10/2011 or with the methods established in the previous legislation (Directive 82/711/EEC of the Council). In other words, it is accepted that until the end of 2015 the tests made in order to write the Declaration of Conformity can be based on the Regulation 10/2011 or the previous legislation.
• From 1st January 2016 it will be accepted to issue a declaration of conformity that indicates the conformity with the Regulation 10/2011, if the supporting documents are based on tests made according to the screening methods or verification methods (overall migration tests, specific migration and residual content) of the Regulation 10/2011.

So, from 1st January 2016, all the plastic articles in contact with food that require migration tests must be tested with the simulants and the exposure conditions indicated in the Regulation 10/2011 and so issue the declaration of conformity.