Is it mandatory to deliver the migration test report to my clients?
We frequently receive enquiries about the migration test report, so we would like to provide a brief explanation from the Food Contact & Packaging Laboratory.
A migration test report is considered one of the justificatory documents according to Regulation (EU) No 10/2011(1). These justificatory documents showcase all the conformity work carried out by the economic operator issuing the Declaration of Conformity (DoC).
According to Article 16 of Regulation (EU) No 10/2011, justificatory documents include test conditions and results, calculations, simulations, and other analyses, as well as safety tests or reasoning demonstrating conformity. This article specifies:
The economic operator must provide appropriate documentation to the competent national authorities, upon request, proving that materials and objects, products in intermediate manufacturing stages, and substances intended for the manufacturing of these materials and objects meet the requirements of this Regulation.
It is important to note that in the Article 16 of Regulation (EC) No 1935/2004(2) and Article 7 of Regulation (EC) No 2023/2006(3) (good manufacturing practices), it is specified that the company’s operator will make justificatory documents available to competent authorities when requested.
Therefore, we can conclude that test reports are justificatory documents that should not pass through the supply chain. The only document that should be distributed is the DoC, prepared correctly according to the guidelines in the legislation.
At AIMPLAS, we provide personalized advice to companies manufacturing materials and articles intended for food contact, including the review of Declarations of Conformity to determine and optimize the necessary tests to demonstrate compliance with the legislation. Feel free to contact us.
Mª Carmen Moreno | Food Contact & Packaging Laboratory