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Most food safety discussions focus on what is inside the package—contamination, adulteration, pesticide residues. Very few focus on what the package itself is doing to the food.

Here is the reality that the food industry rarely communicates clearly: packaging is not inert. Every plastic film, aluminium foil, paper board, rubber gasket, adhesive layer and printing ink that comes in contact with food has the potential to transfer chemical substances into that food. The process is called migration—and unlike microbial contamination, it is invisible, odourless and entirely undetectable without laboratory analysis.

In India, where millions of food products are packaged in materials that have never been migration-tested, this is a significant and largely unaddressed food safety concern.

For food manufacturers, exporters, packaging suppliers and compliance teams, understanding migration testing is no longer optional—it is a regulatory and market-access necessity. SKAS Lab (Shree Krishna Analytical Services) is a NABL-accredited food packaging testing laboratory providing migration and food contact material testing services for manufacturers and exporters across India.

What Is Migration in Food Packaging and Why It Is Misunderstood

Migration is the transfer of chemical substances from packaging material into the food it contains. It occurs across all types of food contact materials—plastics, paper, metals, glass coatings, rubber and composite materials.

What most people get wrong about migration:

It does not require direct liquid contact. Chemical substances can migrate through vapour transfer—a mechanism called gas-phase migration. A food product sealed inside a cardboard box, for example, can absorb mineral oil hydrocarbons evaporating from printing inks on the outer box surface without the food ever touching the ink directly. This is one of the most poorly understood contamination pathways in food packaging.

It is not a one-time event. Migration is a dynamic process that continues throughout the shelf life of the product. Substances migrate more rapidly at higher temperatures, in the presence of fat or acid and over longer contact times. A product that passes migration testing at room temperature may fail when stored in a warm warehouse or transported in an unrefrigerated truck through Indian summers.

Visual inspection and raw material certificates are not enough. A packaging supplier can provide a certificate stating that a plastic film is manufactured from food-grade polymers. That certificate confirms the raw material. It does not confirm the behaviour of the final packaging in contact with your specific food product, under your specific storage and distribution conditions. Only actual migration testing of the food-contact scenario provides that assurance.

The Temperature Problem: Why Indian Supply Chains Make Migration Worse

This is a dimension of food packaging safety that is almost never discussed in the Indian context—and it matters enormously.

Migration rates increase significantly with temperature. The relationship is not linear—doubling the temperature can increase migration rates by a factor of four to ten times, depending on the polymer and the migrating substance.

Consider the typical journey of a packaged food product in India:

• Manufactured and packed at a facility, possibly without climate control
• Stored in a warehouse that may reach 40°C+ during summer months
• Transported in a truck without refrigeration for hours or days
• Stored again at a distributor facility
• Displayed on a retail shelf, sometimes in direct sunlight near glass windows
• Purchased by a consumer who may store it at home without air conditioning
• In some cases—microwaved in the original packaging

At each of these stages, migration is occurring at a rate influenced by the ambient temperature. A packaging system designed and tested for 23°C (the standard European test temperature) may behave very differently across this chain.

For the Indian food industry, this means that migration testing should ideally be conducted at temperatures that reflect actual storage and distribution conditions—not just international default test conditions.

FSSAI Packaging Regulations in India: What Is Currently Required

India's food packaging regulatory framework is governed primarily by the Food Safety and Standards (Packaging) Regulations, 2018, administered by FSSAI. These regulations specify:

• Permitted food contact materials and their conditions of use
• Prohibited substances in food contact plastics
• Labelling requirements for food contact packaging (recycling symbols, food-safe symbols)
• Restrictions on recycled plastics in direct food contact applications

The Bureau of Indian Standards (BIS) has published several relevant standards for testing food contact materials, including IS 9845 for determination of overall migration from plastics and IS 15495 covering specific categories of food contact plastic materials.

However, India's current framework takes a negative list approach—it lists prohibited substances and requires that packaging not contain them above specified limits. The European Union, by contrast, uses a positive list approach under EU Regulation 10/2011 on plastic food contact materials—only substances that have been specifically evaluated and approved may be used. Everything not on the approved list is prohibited by default.

This fundamental difference has significant implications for Indian exporters. A packaging material that is fully compliant under Indian regulations may contain substances that are not on the EU positive list and therefore illegal in European markets. Exporters who discover this at the point of customs inspection face rejection, expensive reformulation and lost commercial relationships.

Understanding this gap and testing accordingly is one of the most commercially important things an Indian food exporter can do before entering European or UK markets.

Specific Migrants That Concern Toxicologists Most

Most food packaging compliance discussions focus on overall migration limits. The more important question—and one that requires specific migration testing—is which individual substances are transferring and at what levels.

Here are the migrants that currently concern food safety scientists most, several of which are almost never discussed in Indian industry content:

1. Mineral Oil Hydrocarbons (MOSH and MOAH)

Mineral oil hydrocarbons enter food packaging through two routes: recycled paperboard and cardboard (which may contain mineral oil-based printing inks from previous use) and lubricants used in food machinery.

They exist as two fractions:

• MOSH (Mineral Oil Saturated Hydrocarbons)—accumulate in human fatty tissue and organs
• MOAH (Mineral Oil Aromatic Hydrocarbons)—several are potentially carcinogenic and genotoxic

MOAH migration from recycled paperboard into food via vapour transfer has been documented in cereals, rice, pasta and other dry goods packaged in cardboard boxes. The European Food Safety Authority (EFSA) has flagged MOAH as a priority concern. India has no specific regulatory limit for mineral oil migration from packaging.

2. Primary Aromatic Amines (PAAs)

Primary aromatic amines can migrate from nylon packaging—one of the most widely used flexible packaging materials in the Indian food industry—particularly when the packaging has been exposed to heat.

Several PAAs are classified as suspected or known carcinogens. Under EU regulations, migration of primary aromatic amines into food must be below 0.01 mg/kg (non-detectable). Indian regulations do not currently specify a comparable limit.

Retort packaging, boil-in-bag products and nylon-based vacuum packaging used for meat and processed foods are the highest-risk applications.

3. Bisphenol A (BPA) and Bisphenol Analogues

BPA migrates from polycarbonate plastics and the epoxy resin linings used in metal cans. It is a well-documented endocrine disruptor interfering with hormonal signalling at very low doses. The EU has banned BPA from food contact materials effective 2025.

Indian regulations restrict BPA but do not match the EU's outright prohibition. As BPA-free alternatives (BPS, BPF) gain market share, early toxicological data suggests some of these substitutes may carry similar risks—a situation regulators and testing laboratories are watching closely.

4. Phthalates from PVC Films

PVC cling films and flexible PVC packaging use phthalate plasticisers to maintain flexibility. Phthalates—particularly DEHP, DBP and BBP—are regulated in the EU with strict migration limits because they are reproductive toxins.

Fatty foods in particular—cheese, meat, oily snacks—absorb phthalates efficiently from PVC packaging. Despite this, PVC cling film continues to be widely used in Indian food retail without routine migration testing.

5. Formaldehyde from Melamine Kitchenware

Melamine tableware and food service items—extremely common in Indian households, restaurants and institutional catering—release formaldehyde and melamine into food, particularly when used with hot food or acidic beverages.

FSSAI has published standards for melamine articles, but enforcement testing is limited. Laboratory analysis consistently detects migration above safe levels in low-cost melamine products, particularly when subjected to repeated heating cycles.

How Migration Testing Is Actually Done in a Laboratory

Understanding the testing process helps manufacturers appreciate why it takes time, why conditions matter and why the results are specific to a food-packaging combination—not universally applicable.

Step 1: Identifying the Food Simulant

Because testing migration with every possible food is impractical, laboratories use standardised food simulants that replicate the chemical properties of different food types:

• Simulant A — Water: represents aqueous, non-acidic foods — used for water, milk, non-acidic beverages
• Simulant B — 3% Acetic Acid: represents acidic foods — used for vinegar, pickles, fruit juices
• Simulant C — 10% Ethanol: represents low-alcohol or alcohol-containing foods — used for wine, beer, dairy
• Simulant D1 — 50% Ethanol: represents high-alcohol content foods — used for spirits, liqueurs
• Simulant D2 — Vegetable Oil: represents fatty foods — used for oils, butter, fried snacks, meat

Selecting the wrong simulant produces a result that does not reflect the actual food-packaging interaction. A packaging material tested only with water simulant, then used with a fatty snack product, provides no meaningful migration data for that application.

Step 2: Contact Conditions (Time and Temperature)

Migration testing is conducted under conditions that simulate the intended use of the packaging—including fill temperature, storage temperature and intended shelf life. For long shelf-life products, accelerated test conditions are used.

Standard contact conditions under EU guidelines:

• 10 days at 23°C—for ambient storage products
• 10 days at 40°C—for extended shelf-life ambient products
• 2 hours at 70°C—for hot-fill applications
• 1 hour at 100°C—for boilable packaging

Step 3: Overall Migration Testing

Overall Migration Limit (OML) testing measures the total mass of all substances that have migrated from the packaging into the simulant. The EU OML limit is 10 mg/dm² (or 60 mg/kg of food). Indian regulations under BIS IS 9845 specify comparable limits.

OML gives a regulatory pass/fail result but does not identify which substances migrated or in what amounts.

Step 4: Specific Migration Testing (SML)

Specific Migration Limit testing uses analytical instruments—GC-MS, LC-MS/MS, ICP-MS—to identify and quantify individual substances of concern in the simulant. Each regulated substance has its own specific migration limit and some have non-detectable requirements.

This is where the real safety information lies, and why SML testing is significantly more technically demanding than OML testing alone.

Step 5: Organoleptic Assessment

Migration is not always about chemical toxicity. Flavour and odour transfer from packaging to food—called organoleptic migration—affects product quality and consumer acceptability even when chemical migration levels are within regulatory limits. Sensory panels evaluate food simulant samples for taste and odour characteristics attributable to the packaging.

Who in India Needs Food Contact Material Testing?

• Food manufacturers and processors using any form of plastic, paper, metal, or composite packaging in direct food contact—which is essentially every food manufacturer.
• Packaging manufacturers and converters who need to substantiate compliance claims made to food brand customers and retail buyers.
• Food exporters whose target markets (EU, UK, US, GCC, Australia) require migration test data and Declaration of Compliance documentation.
• Retail chains and private label brands whose supplier codes increasingly require packaging compliance testing as a condition of listing.
• Restaurant and catering chains using food service packaging, cling films, hot-fill containers and melamine tableware.
• FMCG companies launching new products where a new packaging format or supplier change requires fresh migration testing before market entry.

Why NABL Accreditation Matters for Packaging Migration Testing

Migration testing results are used to make regulatory compliance claims in FSSAI documentation, in export shipments and in customer declarations of compliance. A laboratory report used for these purposes must come from a source that regulators and buyers will accept.

NABL accreditation under ISO/IEC 17025 provides that assurance. It confirms that the laboratory uses validated test methods, calibrated instruments, qualified analysts and documented quality controls—all of which directly affect the accuracy and reproducibility of migration test results.

Reviewing a laboratory's accreditation scope before commissioning packaging testing is essential—the scope should specifically cover the food simulants, contact conditions and analytical methods relevant to your packaging application. SKAS Lab's NABL accreditation scope and certificate details are available for review and confirm the laboratory's approved testing parameters.

For manufacturers and exporters unfamiliar with what NABL accreditation means in practical terms, our detailed article on food adulteration testing methods used by NABL-accredited laboratories explains the standards and quality controls that accredited laboratory results are built on.

Real World Example:- Why Packaging Testing Changes Everything

An Indian spice manufacturer had been exporting to Germany for three years using a nylon/PE laminate pouch. A new EU buyer required a Declaration of Compliance and migration test report before placing the first order. Laboratory testing revealed measurable primary aromatic amine migration above the EU's 0.01 mg/kg non-detectable threshold—the nylon layer in the laminate had never been specifically tested for PAA migration.

The manufacturer had to switch to a tested, PAA-compliant nylon film, retest and delay the first shipment by six weeks. The cost of the migration test was a few thousand rupees. The cost of the delay and reformulation was significantly more—a reminder that proactive testing is almost always the cheaper path.

How Testing Builds Trust in Food Supply Chains

Consumer and buyer trust is built on safety and reliability. When packaging passes through a NABL-accredited testing laboratory, it assures:

• Export buyers can rely on Declaration of Compliance documentation
• Retailers reduce the risk of supplier compliance failures
• Consumers receive food that has not absorbed harmful chemicals from its packaging

Testing is not just a regulatory requirement—it is the foundation of trust across the food supply chain.

FAQs – People Also Ask

1. What is food packaging migration testing?
Migration testing measures the transfer of chemical substances from food packaging into food. It quantifies both the total amount of migrating substances (overall migration) and specific regulated chemicals (specific migration), using standardised food simulants under controlled temperature and time conditions.

2. Is migration testing mandatory under FSSAI regulations?
FSSAI's Food Safety and Standards (Packaging) Regulations, 2018 require that food contact materials comply with specified limits for overall migration and restricted substances. While routine third-party testing is not mandated for every batch, manufacturers are responsible for compliance and regulators and buyers can request substantiation at any time.

3. What food simulants are used in migration testing?
Standard simulants include water (for aqueous foods), 3% acetic acid (for acidic foods), 10% ethanol (for alcoholic foods), 50% ethanol (for high-alcohol foods) and vegetable oil (for fatty foods). The correct simulant is selected based on the food type the packaging will contact.

4. How is Indian food packaging regulation different from the EU?
India uses a negative list approach—prohibited substances are listed and everything else is permitted unless specifically restricted. The EU uses a positive list—only approved substances may be used. This difference means Indian exporters may use packaging that is compliant in India but non-compliant in European markets.

5. Does migration testing apply to paper and cardboard packaging as well?
Yes. Paper and paperboard food contact materials can migrate mineral oil hydrocarbons, inks, adhesives and processing chemicals into food. Recycled paperboard is of particular concern due to mineral oil contamination from previous-use inks.

6. How often should a food manufacturer conduct migration testing?
Testing should be done at product launch, whenever the packaging supplier or material specification changes, when a new food product is introduced into existing packaging, and periodically for quality assurance and regulatory readiness—typically every 2–3 years for stable packaging-product combinations.

7. Can the same packaging be tested once and used across all products?
No. Migration is specific to the food-packaging combination. Packaging tested with a water simulant does not generate valid data for a fatty product. Each distinct food type and storage condition requires its own validated migration assessment.

8. How do I arrange packaging migration testing at SKAS Lab?
Contact the SKAS Lab team through the food packaging testing inquiry page. The team will advise on simulant selection, contact conditions, test scope and report format based on your specific packaging material and food product.

Conclusion

Food packaging is not passive. It is an active participant in food safety—one that can introduce chemical substances into food through migration, transfer flavours and odours, and create compliance failures that are entirely invisible until a laboratory analyses the food-packaging system properly. In India, migration testing is underutilised. Most manufacturers rely on raw material certificates rather than actual migration data. Most retailers accept packaging compliance claims without requiring test evidence. And most consumers have no way of knowing what their packaging is transferring into their food.
This is changing. FSSAI enforcement is strengthening. Export buyers are requiring Declaration of Compliance documentation backed by laboratory data. Retail chains are updating supplier codes. As awareness grows, brands that have proactively tested their packaging will be better positioned than those scrambling to comply after the fact.
The starting point is straightforward: commission migration testing from a NABL-accredited laboratory, understand what is actually transferring from your packaging into your food, and build compliance documentation that protects your brand, your customers and your market access. Explore our full range of food and agricultural testing services, or get in touch with our team to discuss your packaging testing requirements.