ILSI Europe’s “Black and White” reports are a series of science-based guidance documents targeted to the food and beverage industry. The newest report in the series provides a comprehensive introduction to analyzing Non-Intentionally Added Substances (NIAS), which are chemicals that are present in a food contact material (FCM) and can migrate into a food product, but were not purposefully added to the food itself during the production process.

The report considers non-harmonized FCMs, highlighting various FCMs and their unique requirements for analysis of migrants, specifically, Intentionally Added Substances (IAS) or NIAS. The document presents background information on different testing conditions for various FCMs and why the standard tests used for plastics outlined in the European Commission Regulation (EU) No 10/2011 (published in January 2011 and covering plastic materials and articles intended to come into contact with food) are inappropriate in some instances for many non-harmonized FCMs.

Additionally, the report gives an overview of the various analytical techniques available, along with their strengths and weaknesses, as no single technique will detect all NIAS or absolutely quantify all of them. Also outlined is the importance of sampling, with “do’s” and “don’ts.” Finally, the document includes a proposal for communicating along the supply chain, which gains more importance with the stated intention of the European Commission to request details of detected NIAS to be passed to the end user of the article.

The report provides an introduction for non-dedicated analysts willing to understand different potential analytical techniques and the interpretation and relevance of their results. It may also be of interest to risk managers who need to assess the safety of FCMs where differing results may cause issues.

Background 

In 2019, as part of its ongoing support to research on FCMs, the ILSI Europe Packaging Materials Task Force kicked-off an expert group which aimed to provide best practices for identifying and quantifying unknown migrants from FCMs, with widely differing characteristics. The activities of the expert group included sampling and sample preparation, a review of current analytical methods, and a publication on how to report, use, and interpret results. The final document aimed to provide a critique on commonly and uncommonly used analytical techniques.

The areas covered were wide ranging, appealing to readers with varying understanding of the approaches to analyze NIAS. Therefore, in 2021, the expert group decided to prepare two documents, one of which is the present report. The second document is a detailed, high-level review paper that approaches the information laid out in the newly published report with more technical specificity.

ILSI Europe: www.ilsi.eu