United States · Food Contact

Migration Testing in the United States

A practical guide to Migration Testing for food contact sold in the United States: who it applies to, what to prepare, and the mistakes that cause rejection.

Who needs it

Materials must be tested for overall and specific migration into food simulants; Brands selling packaging, tableware, or kitchenware in the United States

Authority

U.S. Food and Drug Administration

Legal basis

21 CFR Part 170

Local representative

The importer is normally responsible for compliance

Timeline

Before sale; testing usually takes weeks

Cost

Migration testing is the main cost

If you do not comply

Withdrawal, recall, and fines

Who needs this

Materials must be tested for overall and specific migration into food simulants
Brands selling packaging, tableware, or kitchenware in the United States

Documents you need

Migration test report
Food contact declaration of compliance
Migration test reports
Material composition and supplier declarations

Compliance checklist

Tick each item as you collect it. Saved in this browser only.

Migration test report
Food contact declaration of compliance
Migration test reports
Material composition and supplier declarations

How to comply

Test migration for the intended food type
Confirm the material is in scope of food contact rules
Review composition against the positive list
Test migration where required

Brief for your lab or agent

Copy this into an email, then edit the product and channel.

Request: Migration Testing — United States
Product category: Food Contact
Authority: U.S. Food and Drug Administration
Legal basis: 21 CFR Part 170

Documents we already have:
  1. Migration test report
  2. Food contact declaration of compliance
  3. Migration test reports
  4. Material composition and supplier declarations

Questions:
  1. Does our product fall under Migration Testing in the United States?
  2. Which test standards or evidence do you accept?
  3. What is the current fee and lead time?
  4. Is a local representative required, and can you act as one?

Cost and timeline

Before sale; testing usually takes weeks.

Migration testing is the main cost.

Common rejection reasons

Migration test uses the wrong simulant
No declaration of compliance
Migration limits exceeded
Non-authorised substance in the formulation

Registration, notification, or certification is not the same as approval. Keep the technical file current and make sure the label, listing, and submitted data match.

Official sources

FAQ

Who needs Migration Testing in the United States?

Materials must be tested for overall and specific migration into food simulants Brands selling packaging, tableware, or kitchenware in the United States.

What documents are required for Migration Testing?

Migration test report; Food contact declaration of compliance; Migration test reports; and material composition and supplier declarations.

What is the first step for Migration Testing?

Test migration for the intended food type. Before sale; testing usually takes weeks.

How long does Migration Testing take?

Before sale; testing usually takes weeks.

How much does Migration Testing cost?

Migration testing is the main cost.

What happens if I sell without it?

Withdrawal, recall, and fines.

Who regulates Migration Testing in the United States?

U.S. Food and Drug Administration.