Food Contact
Materials
Every material that touches food must be safe, compliant, and certified. We make sure it is — across India, the USA, and the Middle East.
Understanding the scope of food contact materials
A food contact material is any material or article intended to come into contact with food — directly or indirectly. This definition is broader than most people realise, and it encompasses every stage of the food chain: manufacturing, processing, packaging, transport, storage, preparation, and serving.
The regulatory framework governing food contact materials is one of the most technically complex in any industry. It spans chemistry, toxicology, material science, and law — and it varies significantly between the United States, India, and the Middle East.
DemandLabs Consulting works exclusively with food contact material manufacturers, exporters, and importers. We understand your products, your supply chain, and your regulatory challenges at a depth that no generalist consultant can match.
- ✓Migration of harmful substances can occur without any visible sign — only testing reveals it
- ✓Non-compliance at import can result in entire shipment rejection and return-to-origin costs
- ✓Label violations can trigger FSSAI market inspection and product seizure in India
- ✓ESMA certification is legally mandatory — products cannot be placed on UAE market without it
- ✓NSF/ANSI 61 is required by most US state regulators — not optional for market access
- ✓Halal FCM certification is an increasingly mandatory commercial requirement across the GCC
What counts as a food contact material
The range is broader than most manufacturers expect — and every category has its own regulatory requirements.
Primary Packaging
Flexible plastic films, rigid plastic containers, glass bottles, metal cans, aluminium foil, paper and board cartons, and composite packaging — all in direct contact with food and fully subject to migration testing requirements.
Processing Equipment
Conveyor belts, mixing vessels, tanks, pipes, valves, gaskets, seals, and pumps used in food manufacturing. Any surface that contacts food in the manufacturing process falls within the FCM framework.
Cookware & Kitchen Equipment
Pots, pans, baking trays, cutlery, utensils, cutting boards, and storage containers for domestic or commercial food preparation. Stainless steel, aluminium, cast iron, and non-stick coatings all have specific requirements.
Coatings & Surface Treatments
Non-stick coatings (PTFE, ceramic, hybrid), lacquers on metal packaging, surface treatments on paper and board, and antimicrobial coatings. Regulated both as the coating material and for their migration behaviour.
Packaging Inks & Adhesives
Printing inks on food packaging (even non-food-contact surfaces) and adhesives in laminates. Both can migrate through or around packaging into food — subject to strict regulatory control in all three geographies.
Single-Use Food Service Items
Cups, plates, trays, straws, food wraps, and cutlery in plastic, paper, or bio-based materials. This category is experiencing significant regulatory change globally as single-use plastic restrictions tighten.
Why migration is the central issue in FCM regulation
The fundamental concern driving FCM regulation is migration — the transfer of chemical substances from a material into the food it contacts. Migration can occur through direct contact, through the vapour phase, or through indirect contact.
Every major regulatory jurisdiction has established a framework for controlling migration — including a positive list of permitted substances, specific migration limits (SML) for regulated substances, and an overall migration limit (OML).
The testing conditions, permitted simulants, and analytical requirements differ between FDA 21 CFR, EU 10/2011 (widely referenced internationally), FSSAI, and ESMA. Getting the test design right before testing begins is critical.
Positive List Assessment
We verify that all substances in your formulation appear on the applicable positive list for your target market — FDA, FSSAI, or GSO.
Test Programme Design
We design the correct migration testing programme — right simulants, right conditions, right analytical methods — before a single test is run.
Lab Coordination
We manage the full testing process with accredited laboratories — sample submission, protocol agreement, result review, and report formatting.
Food contact material sectors we serve
Working with food contact materials?
Whether you are a manufacturer, exporter, importer, or brand owner — if your products come into contact with food, we can help you navigate the regulatory requirements in India, the USA, and the Middle East.
Get a Free FCM Compliance Consultation