--- title: "Food Packaging Migration Testing: OML, SML, Simulants & Buyer Checklist" date: 2026-09-12T12:49:00Z modified: 2026-10-13T01:38:53Z permalink: "https://www.sowintop.com/blog/product-knowledge/food-packaging-migration-testing-guide/" type: post status: publish excerpt: "" wpid: 1731 categories: - product knowledge featured_image: "https://www.sowintop.com/wp-content/uploads/2026/09/image2.jpg" featured_image_alt: Food packaging migration testing with clear salad container on counter timestamp: 2026-10-13T01:38:53Z tags: - product knowledge --- ## **Quick Answer** Food packaging migration testing measures substances transferred from packaging into food or a suitable simulant. This guide compares migration limits, test conditions, and purchasing documents. SOWINTOP supplies compliance documentation for its packaging programs. ## **Why Does Migration Testing Matter for Food Packaging?** ### **Contact Conditions Change the Result** Migration depends on material, food, contact area, temperature, and time. Cold juice and hot takeaway food present different exposure conditions. ![Food-contact testing factors: temperature, contact duration, and food composition.](https://www.sowintop.com/wp-content/uploads/2026/09/image1.jpg) For example, a refrigerated PET juice cup differs from a PP container holding warm, oily food. Our [PET cups and containers guide](https://www.sowintop.com/wp-content/uploads/wp-mfa-exports/post/pet-cups-and-containers-production-and-recycling.md) explains cold-packaging material selection. ### **Jurisdiction Changes the Evidence** EU Regulation 10/2011 sets plastic migration limits and documentation rules. U.S. FDA requirements depend on substance authorization and permitted use conditions. ## **How Do Overall and Specific Migration Limits Differ?** OML vs SML describes what the laboratory measures. | **Test** | **What It Measures** | **How the Result Is Used** | | --- | --- | --- | | Overall migration testing | Total nonvolatile material released into the specified food simulant | Compared with the applicable overall migration limit (OML) | | Specific migration testing | A named substance, or regulated group of substances | Compared with its substance-specific migration limit (SML) | The EU overall limit is **10 mg per dm²** of food-contact surface, with specific exceptions. Each SML depends on the regulated substance or group. Passing OML cannot replace a required SML assessment. Both figures need the correct units and contact-area assumptions before comparison. ## **How Are Food Contact Simulants and Test Conditions Chosen?** ### **Match the Simulant to the Food** Food contact simulants stand in for defined food categories during laboratory testing. EU examples include 10% ethanol (A) for aqueous foods, 3% acetic acid (B) for acidic foods, and vegetable oil (D2) for fatty foods. Other assignments cover alcoholic and dry foods. Annex III assigns simulants by food category, while Annex V governs test conditions and procedures. A clear container sold for both plain salad and oil-based dressing may need a wider assessment than a water-only application. The test plan should reflect the marketed use, not simply the resin name. ### **Match Exposure to Intended Use** Time and temperature represent foreseeable contact, including filling and storage where applicable. When lids contact food, their material matters too. Our [plastic lids materials article](https://www.sowintop.com/wp-content/uploads/wp-mfa-exports/post/what-are-the-different-types-of-plastic-lids.md) explains material and closure choices. ## **How Does EU 10/2011 Documentation Move Through the Supply Chain?** ### **Link the Declaration to Supporting Evidence** The EU declaration of compliance (DoC) identifies the article, restrictions, and conditions of use. Supporting records substantiate it and remain available to enforcement authorities. ![Food packaging compliance workflow linking intended use to supporting evidence.](https://www.sowintop.com/wp-content/uploads/2026/09/image4.jpg) The sequence is **intended use → article specification → tests or calculations → supporting records → DoC**. Generic certificates without a product match leave gaps. Under EU rules, supporting documents substantiate the DoC; the declaration itself is the supply-chain communication document. A report may cover several articles only when its scope and scientific rationale support that grouping. ### **Keep FDA Claims Separate** For U.S. sales, regulated components need applicable authorization for their intended use. An EU DoC alone does not prove FDA status. ## **How Are Cups, Lids, and Containers Sampled?** ### **Define the Contact Surface** The test plan identifies the food-contact side and surface-to-food ratio. Laboratories test filled articles or appropriate specimens. A drink cup, its snap-on lid, and a takeaway container may need different contact assumptions. ### **Match the Tested Article** Material grade, colorant, or coating affects evidence selection. Our [takeaway container materials guide](https://www.sowintop.com/wp-content/uploads/wp-mfa-exports/post/plastic-food-containers-pros-cons-safe-use-guide.md) covers format limits. [ ![PET Cold Drink Cup Lids](https://sowintop.b-cdn.net/wp-content/uploads/2026/04/Frame-4-1.png) PET Cold Drink Cup Lids Eco-friendly PET lids offer superior crack resistance and clarity for cold beverages using sustainable, recyclable materials. View Products ](https://www.sowintop.com/product/pet-cold-drink-cup-lids/) ## **How Can Buyers Read a Migration Test Report?** ### **Review Scope Before the Pass Result** The report identifies the tested article, contact surface, simulant, duration, and temperature. It also lists methods, results, units, limits, and report identifiers. A cold PET cup report cannot automatically support hot filling or a different lid material. ### **Read the Numbers in Context** Compare measured values with stated limits, noting corrections and uncertainty. Check named SML substances alongside the overall result. For example, a result below the overall limit still leaves a named migrant unresolved if its targeted test is absent. Conversely, a single SML pass does not establish the total migration result. ## **What Belongs on an RFQ Compliance Checklist?** ### **Define the Application** Include article dimensions, material, food type, filling temperature, storage period, and destination market. Identify surfaces contacting the contents. ### **Define the Document Set** Specify the DoC or U.S. authorization basis, matching test evidence, and use restrictions. Record design and material variants. ## **How Does SOWINTOP Support a Compliance Review?** SOWINTOP manufactures PP/PET cups, lids, and takeaway containers with OEM/ODM support. We publish a standard 20-day lead time, annual exports above 20 million kilograms, and prepared compliance documentation. [Explore our packaging collection](https://www.sowintop.com/products/) and share the intended food, contact temperature, market, and article specification. **Request SOWINTOP’s applicable test documentation** for the selected cup, lid, or container before approval. [ ![Custom Clear Plastic Cups](https://sowintop.b-cdn.net/wp-content/uploads/2026/03/Plastic-Cups.webp) Custom Clear Plastic Cups Eco-friendly clear plastic cups offer superior clarity for cold beverages using sustainable, plant-based materials. View Products ](https://www.sowintop.com/product/custom-clear-plastic-cups/) ## **Frequently Asked Questions** ### **Does an OML Pass Mean Every Substance Passes?** No. OML measures total release, while an SML applies to a particular regulated substance or group. Both assessments may be necessary for the intended application. ### **Is a Food-Grade Resin Certificate Enough?** No. The finished article’s formulation, geometry, and intended contact conditions determine whether the supporting evidence fits its use. ### **Can One Test Cover Every Food and Temperature?** No. The food category and exposure conditions determine the applicable test plan. A broader claim needs evidence covering the broader intended use. [****Get a**** ****Quote****](https://www.sowintop.com/contact-us/)