Note for Guidance for Food Contact Materials
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Annex 2 to Chapter IV
EXPLANATORY NOTE" ON THE USE OF t-T TABLE IN DIRECTIVE 82/711/EEC AS
AMENDED FOR SELECTION OF CONDITIONS IN MIGRATION TESTING
(called briefly "Guidelines for Selection of Test Conditions")
NOTA BENE: This appendix was prepared by TNO under EC contract.
It has already become evident that the text of Chapter II of Directive 93/8/EEC needs some
elucidation in order to make interested parties better understand how to select conditions in
migration testing (simulant, time and temperature) that would match conditions of contact
between foodstuffs and food contact materials in practice.
In order to meet this need an inventory was drawn up in the first place by the Commission
Services of conditions of contact between foods and food contact materials practised in the food
industry in preparing and storage of packed foods.
Subsequently the data collected was entered into a table which is similar to the one in Directive
85/572/EEC for the classification of foodstuffs.
The contact time in actual use, as presented in the table, are assumed to represent maximum
In the table conditions for testing such as food simulant, time and temperature are proposed that
match the conditions of contact in practice of food and food contact material.
In case of multi-layer materials the contact material is mentioned first (e.g. paper/alufilm). In
many cases the packaging consists of various parts that all are in contact with the food (e.g.
plastic film/plastic tray). In that case each part should be subject to migration testing.
For the sake of completeness, packaging materials, like glass or coated board, are included
which are not yet covered by an EC Directive. These materials are not yet subject to migration
It goes without saying that the list of packed foods in the table is not complete. Interested parties
are invited to provide the Commission Services with additional information which would allow
the table to be corrected where necessary and to enlarge the number of examples. Cooperation of
several experts in food industry as well as of retail store managers in drafting the guidelines is
Explanation of expressions and abbreviations