European legal limits for migration from food packaging materials: 1. Food should prevail over simulants; 2. More realistic conversion from concentrations to limits per surface area. PVC cling films in contact with cheese as an example

Abstract For small packs with a high ratio of contact surface area/volume, present European legislation tolerates extremely high migration in terms of concentration in the food, since limits apply as migration per surface area. Overall migration (OM) may exceed 1000 mg/kg, which is orders of magnitude above the tolerance for any other type of food contaminant. With the present rules for specific migration (SM), the tolerable daily intake (TDI) may be exceeded with less than 100 g food, particularly when a fat consumption reduction factor (FRF) is applied. The OM and the SM of di(2-ethylhexyl) adipate (DEHA) from PVC cling films into cheese demonstrate that such high migration is not just a theoretical extrapolation, but is encountered in reality. Another problem concerns possible inaccuracy of migration testing with simulants. Even when the migration into the food is known to be almost complete, simulant D reduction factors (DRFs) are applied. The following measures are suggested: 1. The legal limits in terms of concentration in food should be converted to migration per contact surface area by a ratio which no longer focuses on the 1 l cube, but on the current smaller packs. It is proposed to assume 20 dm 2 contact surface area per liter of packaging volume, i.e. the OML of 60 mg/kg should correspond to 3 mg/dm 2 . 2. Legal limits should apply in terms of concentrations down to a contact surface area/volume ratio of 20 dm 2 /l, below which they should be calculated per surface area. 3. For compliance testing, migration into food should explicitly prevail over migration into simulants. These modifications will ensure that the overall migration exceeds the 60 mg/kg in food only for packagings with a high surface area to volume ratio and that with normal consumption, the TDI can still be approached rather easily, but not strongly exceeded.