Food Contact Plastics in India: FSSAI, IS 10146 and Migration

“Food grade” is not a property that a plastic either has or does not have. It is a conclusion reached about a particular material, made to a particular formulation, in contact with a particular food, at a particular temperature, for a particular time. Change any of those and the conclusion has to be re-examined.

This is the single most common misunderstanding in Indian food packaging, and it produces both unnecessary rejections and genuinely non-compliant products.

The regulatory structure

FSSAI – the Food Safety and Standards Authority of India – regulates food packaging under its packaging regulations. The framework requires that materials used in contact with food comply with the relevant Indian Standards, and it sets out overall and specific migration requirements.

The IS standards that carry the technical detail include:

Standard	Covers
IS 10146	Polyethylene in contact with foodstuffs
IS 10910	Polypropylene in contact with foodstuffs
IS 10151	Polyvinyl chloride in contact with foodstuffs
IS 12252	Polyalkylene terephthalates (PET) in contact with foodstuffs
IS 10142	Polystyrene in contact with foodstuffs

Each specifies permitted materials, additives and test requirements for that polymer family. The colourant is within scope – it is part of the material in contact with food, not an accessory to it.

Exporters face additional regimes. EU Regulation 10/2011 for plastics in food contact, and the US FDA’s food contact substance framework, are the two most commonly requested. They do not align perfectly with the Indian requirements, so a product compliant in India is not automatically compliant for export.

Confirm which regime your customer means before issuing any declaration. “Food grade” on a purchase order is not a specification.

How migration testing works

The principle is straightforward: rather than testing against every possible food, testing uses food simulants that represent classes of food.

Typical simulants:

Simulant	Represents
Distilled water	Aqueous foods
Dilute acetic acid	Acidic foods
Ethanol solutions	Alcoholic and fatty foods
Vegetable oil or a substitute	Fatty foods

The sample is exposed to the simulant under defined time and temperature conditions chosen to represent the intended use – refrigerated storage, ambient, hot fill, or reheating – and then two things are measured:

Overall migration – the total mass of everything transferring into the simulant, against a limit expressed per unit area or per unit food mass. It answers “is this material generally stable in contact with food”.

Specific migration – the quantity of a particular substance of concern, against a substance-specific limit. It answers “is this specific ingredient a problem”.

Test conditions are part of the result. A material that passes at refrigeration temperature may fail at hot-fill temperature. Fatty food simulants are the most aggressive for most plastics, because many additives and some pigment residues are more soluble in fat than in water. A pack cleared for dry snacks is not thereby cleared for ghee.

What this means for colourants

Pigments are assessed on migration, not only on composition. The same principle that governs toy safety applies: what matters is what comes out under the test conditions.

Most pigments used in plastics are large, insoluble particles that do not migrate meaningfully. The things that do migrate are usually:

– Soluble dyes, which by definition are dissolved in the polymer and mobile – Additives in the masterbatch – dispersing agents, processing aids, slip, antistatic, anti-fog – all of which are designed to be mobile or surface-active – Residual monomers and low molecular weight fractions from the carrier – Heavy metal impurities in poorly controlled pigments

The additives are usually the risk, not the pigment. A migratory antistatic or anti-fog additive is engineered to move to the surface, which is exactly where the food is. Those additives need specific food-contact clearance at the loading used – see antistatic masterbatch and anti-fog additives.

Recycled content is the hardest case. Recyclate carries an unknown history, and food contact regulation is built on knowing what is in the material. Food-contact recycled plastic requires a properly controlled and approved recycling process with traceable input streams. Bottle-to-bottle rPET is the mature example; most other recycled streams are not cleared for direct food contact. See masterbatch for recycled and PCR plastic and EPR for plastic packaging, where the recycled content obligation and the food contact restriction pull in opposite directions.

The declaration chain

Compliance is established for the finished article, and it depends on every input.

What a masterbatch supplier can provide: – A declaration that the formulation is composed of substances suitable for food contact under a named regime – The regime and version assessed against – Test data on the concentrate or on standard plaques – Notification of formulation change

What the converter must establish: – That the finished pack complies at the actual loading, in the actual polymer, at the actual thickness, with the actual food, under the actual conditions

Neither party can do the other’s part. A masterbatch declaration is a required input to a compliance file; it does not certify a pack. Equally, asking a colourant supplier to certify a finished package they have never seen is asking for a document with no meaning.

Practical points that cause failures

Thickness matters. Migration limits are expressed per unit area of contact or per unit mass of food. A thin film in contact with a large mass of food is a different case from a thick container holding a small quantity.

Temperature matters more than most people assume. Migration rises steeply with temperature. Hot fill, retort and microwave applications are materially different from ambient storage and need their own assessment.

Duration matters. A pack for two days of chilled storage is not the same case as one for a two-year shelf life.

Reuse changes everything. Repeated washing and refilling means repeated exposure, and washing chemicals attack the surface. Reusable containers need assessment on that basis.

Regrind is a hidden risk. Regrind from a non-food line entering a food line breaks the chain entirely. Segregation is a compliance control, not housekeeping.

Change control is where files break down. A pigment substitution by a supplier can invalidate a declaration silently. Write notification obligations into purchase agreements.

Building a defensible file

1. Identify the regime – FSSAI and the relevant IS standards, plus any export requirement 2. Define the use case – food type, contact temperature, contact duration, thickness 3. Collect declarations for every input including polymer, masterbatch and additives 4. Test the finished article against the appropriate simulants and conditions at an accredited laboratory 5. Control regrind and segregation with documented procedures 6. Write change notification into every material purchase agreement 7. Review periodically, because regulations and lists are updated

Talk to us

Life Color Pigments & Masterbatches supplies colour, white and additive masterbatches for food packaging applications, manufactured under ISO 9001:2015, with declarations against the named regime where the application requires them.

Tell us the food type, the contact temperature and duration, your polymer and thickness, and the regime you certify to – a formulation built for ambient dry goods and one built for hot-fill fatty food are not the same product.

Related: packaging, pharma, household, PET preform and bottle masterbatch.

FAQs

What does food grade plastic actually mean? Not a fixed property of a polymer. It is a conclusion about a specific material and formulation, in contact with a specific food type, at a specific temperature, for a specific duration and at a specific thickness. Change any of those and the assessment must be revisited.

Which Indian standards cover food contact plastics? FSSAI packaging regulations set the framework, referencing Indian Standards for each polymer family – IS 10146 for polyethylene, IS 10910 for polypropylene, IS 10151 for PVC, IS 12252 for PET and IS 10142 for polystyrene, among others.

What is migration testing? Exposing the material to food simulants – water, dilute acetic acid, ethanol solutions and a fatty simulant – under defined time and temperature conditions, then measuring overall migration of everything transferred and specific migration of substances of concern against set limits.

Which food simulant is most aggressive? Fatty food simulants, for most plastics, because many additives and some pigment residues are considerably more soluble in fat than in water. A pack cleared for dry or aqueous foods is not automatically cleared for oil, ghee or fatty products.

Are pigments a food contact risk? Usually less than the additives. Most pigments are large insoluble particles that do not migrate meaningfully. Soluble dyes, and mobile additives such as slip, antistatic and anti-fog agents, are the more common source of migration because they are designed to move.

Can recycled plastic be used for food contact? Only through a properly controlled and approved recycling process with traceable input streams. Bottle-to-bottle rPET is the mature example. Most other recycled streams are not cleared for direct food contact, because food contact regulation depends on knowing what is in the material.

Does a masterbatch food contact declaration certify my packaging? No. It is a necessary input to your compliance file. Compliance is established for the finished article at your loading, in your polymer, at your thickness, with your food, under your conditions – which only you can test.

Why does regrind matter for food contact compliance? Because regrind from a non-food line introduces material of unknown history into a food-contact product, breaking the traceability the whole regime depends on. Segregation of food and non-food regrind is a documented compliance control, not just good housekeeping.