Overall Migration Testing Services in India
NABL-accredited Overall Migration Testing that verifies your food contact packaging stays within the Overall Migration Limit (OML) — before it ever reaches a shelf, a customer, or a customs inspector.
Every piece of packaging that touches food is also, technically, an ingredient. Plastics, laminates, coatings, and closures are formulated from monomers, additives, plasticisers, stabilisers, and printing inks — and under conditions of heat, time, fat content, or acidity, components of that packaging can transfer into the food or beverage it contains. This transfer is called migration, and Overall Migration Testing is the laboratory method used to measure the total quantity of non-volatile substances that move from a food contact material into food or an approved food simulant.
For food manufacturers, beverage companies, and packaging suppliers, migration is not a theoretical risk. It is a measurable, regulated parameter that determines whether a packaging material is fit for its intended food-contact use. Packaging that releases excessive quantities of migrating substances can compromise food safety, alter taste and odour, and expose manufacturers to regulatory rejection, product recalls, and reputational damage — particularly in export markets where food contact material (FCM) compliance is verified before a shipment is allowed to clear customs.
Overall Migration Testing sits at the intersection of three priorities that every manufacturer and brand owner must satisfy simultaneously:
Consumer Safety
Ensuring that packaging does not introduce harmful or undesirable substances into food at levels that pose a health risk.
Product Quality
Protecting flavour, aroma, and shelf stability from packaging-derived contamination.
Regulatory Compliance
Meeting the Overall Migration Limit (OML) prescribed under Indian standards (FSSAI and BIS) and international frameworks such as EU Regulation (EU) No. 10/2011 and US FDA food contact material regulations.
The Fair Labs provides NABL-accredited Overall Migration Testing for plastic, flexible, and multilayer packaging materials used across food, beverage, pharmaceutical, and cosmetic applications — generating the laboratory evidence manufacturers need to validate packaging safety, support regulatory submissions, and satisfy buyer and export documentation requirements.
Packaging decisions are frequently made on cost, barrier performance, and shelf appeal — and migration compliance is treated as a downstream formality to be confirmed later. In practice, this sequencing creates risk. A packaging format selected, tooled, and printed without prior migration verification can fail testing only after significant capital has already been committed, forcing a costly reformulation or resourcing exercise. Building migration testing into the packaging selection and supplier qualification process — rather than treating it as a pre-launch checkbox — is the more defensible and economically sound approach for manufacturers operating at any meaningful scale.
What is Overall Migration Testing?
Overall Migration Testing is a standardised laboratory test that measures the total mass of substances — across all chemical classes combined — that migrate from a food contact material into a food simulant under defined, intended conditions of use (typically a specific temperature and contact time that mimics real-world storage or use of the packaged product).
Unlike tests that target a single named substance, Overall Migration Testing produces a single aggregate figure: the total quantity of non-volatile material that has transferred from the packaging into the simulant, usually expressed in milligrams per square decimetre of contact surface area (mg/dm²) or milligrams per kilogram of food (mg/kg).
The Overall Migration Limit (OML)
The Overall Migration Limit (OML) is the maximum permissible quantity of total migrating substances allowed under applicable regulation. Under both Indian and EU frameworks, the commonly referenced OML for plastic food contact materials is 10 mg per dm² of food contact surface area, or its equivalent expressed per kilogram of food, depending on the product category and applicable standard. A packaging material that exceeds this limit is considered non-compliant for its intended food-contact application, regardless of which specific substances make up the migrated mass.
Food Simulants
Because testing migration directly into every possible food product is impractical, regulatory frameworks define a set of standardised food simulants — liquids chosen to represent the chemical behaviour of different food categories (aqueous, acidic, alcoholic, and fatty foods). Packaging is tested by bringing it into contact with the appropriate simulant(s) for a defined time and temperature, after which the simulant is analysed to quantify the migrated residue.
Migration Under Intended Conditions of Use
A defining feature of Overall Migration Testing is that it is always conducted under conditions that replicate the packaging's intended end use — not arbitrary or worst-case conditions. A container intended for ambient storage of dry snacks is tested differently from a container intended for hot-fill dairy products or microwave reheating, because temperature and contact time are the primary drivers of migration rate. Selecting the correct test condition is therefore a critical step that directly affects whether results are regulatorily meaningful.
Food Contact Materials (FCMs)
Food Contact Materials include any material or article intended to come into contact with food — plastic containers, films, laminates, caps, closures, coatings, printed packaging, and multilayer structures. Each of these material types carries a distinct migration profile depending on its polymer composition, additive package, and manufacturing process.
Why Migration Occurs
Migration occurs because packaging polymers are not chemically inert. Low-molecular-weight substances such as residual monomers, plasticisers, antioxidants, slip agents, and processing aids are mobile within the polymer matrix and can diffuse toward the food-contact surface over time, particularly when accelerated by heat, fat content, or prolonged contact. The rate and extent of this diffusion depend on polymer type, additive concentration, contact temperature, contact duration, and the chemical nature of the food itself.
Overall Migration vs. Specific Migration
This distinction is frequently misunderstood, so it is worth stating clearly:
| Aspect | Overall Migration Testing | Specific Migration Testing |
|---|---|---|
| What it measures | Total mass of all non-volatile substances migrating, combined | Concentration of one specifically named substance (e.g., a particular monomer or additive) |
| Result expressed as | Aggregate mg/dm² or mg/kg | Individual substance concentration against its own specific migration limit (SML) |
| Purpose | Screens overall packaging "cleanliness" and inertness | Verifies compliance for substances with known toxicological limits |
| When required | Generally required for all food contact plastics | Required when specific regulated substances are present in the formulation |
Both tests are frequently required together, since a packaging material can pass Overall Migration Testing while still requiring Specific Migration Testing for a named substance of toxicological concern — and vice versa.
Why Overall Migration Testing Matters
Consumer Health
The OML acts as a precautionary ceiling on the total chemical burden a food contact material can transfer, particularly relevant for infants, children, and repeated consumption of a packaged food category.
Regulatory Compliance
Non-compliant packaging can result in regulatory action against the food product itself, even when the food formulation is otherwise compliant — contamination from packaging is treated as a food safety failure.
Sensory Quality
Excessive migration can cause "organoleptic taint" — altering taste, odour, and appearance — a quality issue independent of toxicological risk.
Brand Protection
A packaging-related recall or "off-taste" complaint is reputationally costly. Proactive testing is materially cheaper than managing a post-launch failure.
Import & Export Requirements
Migration documentation is frequently requested by overseas buyers and customs authorities, especially for EU and US shipments. Gaps invite detention risk and heightened future scrutiny.
Retailer Compliance
Organised retail chains and private-label commissioning brands now require migration reports as standard vendor qualification, independent of statutory requirement.
Food Packaging Quality Assurance
For packaging manufacturers themselves, Overall Migration Testing functions as a quality assurance checkpoint — confirming that raw material selection, additive formulation, and manufacturing process consistently produce food-contact-safe output, batch after batch. Periodic re-testing, rather than a single one-time qualification, is the more defensible practice where raw material sourcing or formulation is subject to change over time.
Applicable Regulations and Standards
Food contact material compliance is governed by a layered set of national and international standards. The applicable framework depends on the destination market, the packaging material type, and the food category involved.
Regulatory Note: Compliance with one market's framework does not automatically satisfy another's. A packaging material approved for FSSAI compliance in India may still require additional testing against EU or US FDA parameters before export, due to differing simulant protocols, test conditions, and permitted substance lists.
FSSAI
The Food Safety and Standards Authority of India regulates food packaging materials under the Food Safety and Standards (Packaging) Regulations, 2018, which incorporate migration limits and testing requirements, referencing applicable BIS standards for test methodology.
Bureau of Indian Standards
Several IS standards govern testing methodology and compliance criteria: IS 9845 (overall migration requirements and conditions for plastics), IS 10146 (polyethylene as food contact material), IS 10142 (PVC in contact with foodstuffs), IS 10910 (polypropylene as food contact material), and IS 12252 (plastic materials and articles intended to contact food generally, including migration parameters).
EU Regulation (EU) No. 10/2011
The principal EU regulation governing plastic food contact materials and articles, prescribing the OML of 10 mg/dm², approved simulants, standard test conditions, and a positive list of authorised substances for plastic formulations.
Framework Regulation (EC) No. 1935/2004
Establishes the general principle applicable across all food contact materials in the EU — not just plastics — requiring that materials do not transfer constituents to food in quantities that endanger health, change food composition unacceptably, or deteriorate organoleptic characteristics.
US FDA Food Contact Material Regulations
Food contact substances are regulated under the Federal Food, Drug, and Cosmetic Act, primarily through Food Contact Notifications (FCNs) and listings under 21 CFR Parts 174–186, governing indirect food additives including packaging components and their permitted migration behaviour.
Why Multi-Market Compliance Matters
A manufacturer supplying both the domestic Indian market and export destinations should expect to test packaging against more than one regulatory framework, since simulant selection, test temperature/time combinations, and even the definition of the OML itself can differ between jurisdictions. The Fair Labs structures testing programmes around the destination market(s) a client actually serves, rather than applying a single default protocol.
Packaging Materials We Test
The Fair Labs performs Overall Migration Testing across the full range of food-contact packaging formats in current commercial use:
Each material category presents a distinct migration profile depending on polymer chemistry, layer structure (in the case of laminates and multilayer packaging), and intended use temperature — and testing protocols are configured accordingly.
Our Overall Migration Testing Parameters
Food simulant selection and test conditions are matched to the packaging's intended food category and conditions of use. The table below summarises commonly applied simulants and conditions.
| Food Simulant | Represents | Typical Test Conditions | Applicable Packaging | Purpose |
|---|---|---|---|---|
| Distilled Water | Aqueous, non-acidic foods | 10 days at 40°C (or as per intended use) | Containers for water, dairy, low-acid beverages | Assesses migration into neutral aqueous food matrices |
| 3% Acetic Acid | Acidic foods | 10 days at 40°C (or hot-fill equivalent) | Sauces, pickles, acidic beverages, fruit-based products | Assesses migration into acidic food matrices |
| 10% Ethanol | Aqueous/alcoholic foods | 10 days at 40°C | Beverage packaging, alcoholic and low-alcohol drinks | Represents low-alcohol-content food and beverage products |
| 50% Ethanol | Fatty/alcoholic foods | 10 days at 40°C or as per category | High-fat or alcoholic food products | Approximates fatty food behaviour where oil simulant is impractical |
| Vegetable Oil (or approved substitute) | Fatty foods | 10 days at 40°C, or 2 hours at 175°C for high-temperature use | Containers for oils, fats, fried or fatty foods | Assesses migration into fat-based food matrices, typically the most demanding condition |
Test temperature and duration are adjusted to reflect realistic conditions of use — for example, ambient storage, refrigeration, hot-fill processing, or microwave reheating — rather than applying a single uniform condition across all packaging types. Selecting the correct simulant and condition combination is essential to producing a result that is both scientifically valid and regulatorily defensible.
Our Testing Process
The Fair Labs follows a structured, traceable workflow for every Overall Migration Testing engagement:
1. Sample Submission
Packaging samples are submitted by the client, either through pan-India courier or direct laboratory drop-off, accompanied by details of the intended food contact application.
2. Packaging Evaluation
Our technical team reviews the material type, intended food category, and conditions of use to determine the appropriate regulatory framework and test protocol.
3. Selection of Food Simulant
Based on the packaging's intended contents (aqueous, acidic, alcoholic, or fatty), the correct simulant(s) and test conditions are selected in line with applicable standards.
4. Migration Test
The packaging sample is brought into controlled contact with the selected simulant for the specified time and temperature, replicating real-world conditions of use.
5. Laboratory Analysis
The simulant is analysed using validated gravimetric and analytical methods to quantify the total migrated residue.
6. Result Interpretation
Results are evaluated against the applicable Overall Migration Limit for the relevant market and packaging category.
7. Compliance Report
A formal, NABL-accredited test report is issued, documenting methodology, results, and compliance status — suitable for internal QA records, regulatory submission, or buyer documentation.
Common Migration Testing Mistakes Manufacturers Make
Callout: Most migration compliance failures are not caused by genuinely unsafe packaging — they are caused by avoidable errors in how testing is scoped, conducted, or interpreted. The patterns below account for the majority of issues The Fair Labs sees during packaging qualification work.
- Testing against the wrong simulant. Selecting a generic simulant rather than one matched to the actual food category — for example, testing a fat-contact container only against aqueous simulant — produces results that understate real-world migration risk.
- Using test conditions that don't reflect actual use. A container intended for hot-fill or microwave use tested only under ambient conditions will not surface migration behaviour that emerges at higher temperatures.
- Treating a one-time test as permanent qualification. Packaging formulations, resin suppliers, and additive packages change over time, often without the food brand being notified by their packaging vendor. A migration result from two years ago does not necessarily reflect current production.
- Assuming domestic compliance covers export markets. FSSAI/BIS compliance and EU or US FDA compliance are not automatically interchangeable, given differences in simulant protocols and permitted substance lists.
- Overlooking printed and laminated layers. Migration testing focused only on the primary polymer layer can miss contributions from inks, adhesives, and coatings used in multilayer or printed packaging.
- Skipping testing on closures and caps. Caps, lids, and seals are food-contact components in their own right and are sometimes excluded from migration testing programmes that focus only on the primary container body.
Industries We Serve
Why Choose The Fair Labs
Testing performed under ISO/IEC 17025 accreditation, ensuring internationally recognised technical competence.
A dedicated technical team experienced specifically in packaging migration chemistry, not just general food testing.
Instrumentation capable of accurate gravimetric and trace-level analysis across all standard food simulants.
Testing aligned to IS standards, EU Regulation (EU) No. 10/2011, and US FDA protocols, configured to the client's target market.
Analysts with hands-on experience interpreting migration data against multiple regulatory frameworks.
Defined turnaround commitments structured around production and shipping schedules.
Audit-ready documentation suitable for regulatory submission, buyer due diligence, and customs clearance.
Logistics support for sample collection and submission from manufacturing units nationwide.
Guidance on simulant selection, test condition matching, and packaging formulation adjustments where results indicate non-compliance.
Frequently Asked Questions
Overall Migration Testing is a laboratory method that measures the total quantity of non-volatile substances migrating from a food contact material into food or an approved food simulant under defined conditions of use, expressed as an aggregate figure rather than substance-by-substance.
The OML is the maximum permissible total migration from a food contact material into food or simulant, commonly set at 10 mg per dm² of contact surface area under both Indian and EU frameworks, though specific limits can vary by category and market.
It is required to confirm that food packaging does not transfer excessive quantities of chemical substances into food, protecting consumer health, preserving product quality, and meeting regulatory obligations under FSSAI, BIS, and applicable export-market standards.
Overall Migration Testing measures the total combined mass of all migrating substances, while Specific Migration Testing quantifies an individually named substance against its own defined limit. Both are often required together for a complete compliance picture.
Any plastic, flexible, or multilayer packaging material intended for food contact — including bottles, containers, films, laminates, pouches, cups, trays, and caps — should be tested before commercial use, particularly when packaging formulation, supplier, or intended food category changes.
Commonly used simulants include distilled water, 3% acetic acid, 10% ethanol, 50% ethanol, and vegetable oil or an approved substitute, selected based on whether the intended food is aqueous, acidic, alcoholic, or fatty.
Packaging materials intended for food contact use in India are expected to comply with migration requirements under the Food Safety and Standards (Packaging) Regulations, 2018, which reference applicable BIS test standards — making compliance an expected part of bringing food packaging to market.
Food and beverage manufacturers, dairy producers, snack and ready-to-eat food companies, pharmaceutical and cosmetic manufacturers, and packaging suppliers and exporters all routinely require migration testing as part of packaging qualification.
Turnaround depends on the simulant, test condition, and packaging category, since some protocols require extended contact periods (such as 10-day simulant exposure) to replicate realistic conditions of use. The Fair Labs confirms exact turnaround at the time of sample booking.
Yes. NABL ISO/IEC 17025 accreditation is widely recognised by regulators, buyers, and customs authorities as evidence of a laboratory's technical competence, which is why migration test reports from accredited laboratories such as The Fair Labs are commonly used to support compliance documentation.
Get Your Packaging Tested
Packaging that hasn't been verified against the Overall Migration Limit is an open question mark on every shipment, every retail listing, and every regulatory audit. Close that gap before it becomes a problem.
Service Inquiry
We'll get back to you within one business day.
Inquiry Received!
Thanks — our team will reach out to you shortly regarding your selected service.