Smithers Pira responds to FEICA guidance on adhesive migration tests

On 27 May, the Association of the European Adhesive and Sealant Industry (FEICA) published a new advisory document on conformity testing adhesives in food contact materials.

On 27 May, the Association of the European Adhesive and Sealant Industry (FEICA) published a new advisory document on conformity testing adhesives in food contact materials.

Commenting on its publication, food contact legislative expert Alistair Irvine asserts that "The FEICA guidance document is a welcome contribution to help industry establish the suitability of adhesives in food contact applications. As adhesives are not currently covered by harmonised EU legislation there have previously been no well-defined testing rules."

The 12 page free-to-download guidance paper – Migration Testing of Adhesives Intended for Food Contact Materials  – has been issued as part of a broader FEICA project on food contact. 

It recommends tests using the food simulant Tenax to track migration. The document has been prepared by FEICA’s Paper and Packaging Technical Working Group, and while there is a focus on these materials, other packaging substrates are also considered.

The authors state: “Due to the wide range of applications and the complexity of the chemistry, no unified testing conditions can be defined for adhesives,” and that while some provision is made for those used with plastics in the EU Regulation 10/2011 these have “limitations.”

Alistair notes "The approach suggested is based on that taken by the European Commission for regulation of plastics; it therefore has a good degree of consistency with the existing regulatory practise," he continues, "It recognises the differences between the different classes of adhesives and tailors the migration testing approach to match them."

Separate guidance and considerations are given for testing:

  • Polyurethane-based adhesives 
  • Vinyl acetate polymers (PVAc) or ethylene vinyl acetate (EVA) copolymer adhesives
  • Natural polymer-based adhesives
  • Acrylic polymers adhesives 
  • Cold seals
  • Hot seals
  • Hot-melt adhesives.

The new guidance paper joins other advisory documents published by FEICA – including its 2014 Guidance for a food contact status declaration for adhesives; and its 2015 Guideline for Good Manufacturing Practice of food packaging adhesives.

"Taken together with the other documents FEICA has developed on food contact adhesives (on GMP and Declarations of Compliance), it is beginning to form a useful body of guidance." Alistair concludes.

The Smithers Pira team advises clients on the safety legislation which applies to food packaging in a wide range of different countries throughout the world. 

Find out more

Contact Alistair Irvine >

Regulatory Compliance> 

EU Regulations>