Food Contact Materials (FCM) Compliance and Testing

Food contact materials (FCM) are packaging, containers, kitchenware and machine parts that touch food. They must not transfer their constituents to food in quantities that could endanger health or change the food. In the European Union the basic rules are set by Regulation (EC) No 1935/2004. Turkey applies aligned rules through the regulation on materials and articles in contact with food, issued by the Ministry of Agriculture and Forestry. A manufacturer who sells such products in Turkey or the EU, or an importer who brings them into Turkey, has to be able to show compliance with test reports and a declaration of compliance.

For food contact materials compliance, apply to CE Danışmanı (CE Consultant); we manage the whole process for you.

Which products are covered?

• Packaging materials: plastic containers, glass bottles, metal cans, paper and board packaging, composite materials
• Kitchenware: plastic plates and bowls, silicone articles, wooden chopping boards, metal cutlery
• Food processing equipment: food preparation machines, stainless steel worktops, inner surfaces of refrigerators and freezers
• Beverage packaging: PET bottles, aluminium cans, glass bottles, closures
• Single-use products: paper cups, plastic cutlery, aluminium foil, cling film
• Raw materials: plastic granules, coatings and printing inks intended for food contact applications

Requirements by material

Which tests apply also depends on the type of food (aqueous, fatty, acidic, alcoholic or dry) and on the temperature and duration of contact. The three most common groups are:

• Overall migration: the total amount of substances passing into food
• Specific migration: individual substances such as bisphenol A, phthalates and heavy metals
• Sensory tests: whether the material changes the taste or smell of the food

How the process works

1. Define the product and its use. Material composition, food types, contact temperature and time.
2. Sampling and testing. Samples are sent to an accredited laboratory for migration and sensory tests.
3. Technical documentation. Material composition, production flow, quality control procedures and test reports are put together.
4. Assessment. The test results are compared with the limits in the legislation.
5. Declaration and labelling. A written declaration of compliance is drawn up, and the product is marked with the glass-and-fork symbol or with the words “for food contact”.

How long does testing take?

A typical test programme takes 2 to 4 weeks: about one week for sample delivery and preparation, one to two weeks for overall and specific migration tests, and about one week for the report and its evaluation. For complex products such as multilayer packaging or special coatings it can extend to 6 to 8 weeks. A laboratory accredited by TÜRKAK (the Turkish Accreditation Agency) or by an accreditation body in the EU should be used.

When the legislation changes, for example when new migration limits are published in the EU, additional tests may be needed. The same applies when the material, the supplier or the process changes.

Labelling

Articles that are not yet in contact with food when sold must be identified as suitable for food contact, with the glass-and-fork symbol or a written statement. The documentation behind the product identifies the product, the brand and the manufacturer, and must be available to authorities and business customers on request.

Food contact compliance and CE marking

These are two different subjects. CE marking shows compliance with EU product legislation such as the Low Voltage Directive, the EMC Directive or the Machinery Directive. Food contact compliance concerns only the parts that touch food and is based on Regulation (EC) No 1935/2004 and migration limits. Some products need both. A food processing machine, for example, carries the CE marking as a machine, and its food contact surfaces must also comply with the food contact rules. See CE marking for machinery.

Importing into Turkey

Food packaging and other articles in contact with food are subject to official controls when imported into Turkey. The importer is asked for the manufacturer’s declaration of compliance and for test reports. Missing or outdated documents are the usual reason for delays, so the file should be complete before shipment.

How CE Danışmanı helps

• Identifying which rules and tests apply to your material and its intended use
• Coordinating tests with accredited laboratories
• Preparing the technical documentation and the declaration of compliance
• Test protocols and reports aligned with EU requirements for exporters