Expert knowledge

Food & Food Contact Materials

In a globalised world, food and food commodities crossing borders is daily business. But of course this doesn't work without complying to certain standards.

knoell Food and Food Contact Materials

Food Contact Materials

A Food Contact Material (FCM) is any substance or material that comes into contact with food as part of packaging, holding, or processing, but is not intended to be added directly to, become a component, or have a technical effect in or on the food. Food contact materials are also referred to as indirect food additives and need to be authorised for use as per the appropriate country regulations (e.g. EU, United Kingdom, USA, Canada, MERCOSUR, China, Japan, Switzerland etc.).

These regulations exist so that manufacturers and producers of materials such as plastic, paper, paperboard, printing ink, ceramic, wood, metal, cork, textiles, adhesives are utilising materials that are safe for their intended food contact application. If a food contact material is not already regulated, one might need to apply for an authorisation in a given country in order to have this new food contact substance included in an existing positive list and thus cleared for use. Find more information in our Q&A section on food contact materials.

knoell regulatory experts will provide a comprehensive solution in the interpretation of global food contact regulations, implementation of required regulatory reviews and notifications, analytical testing, and toxicology assessments to ensure compliance and safe use of food contact materials.

Our team of experienced experts will provide our clients with

FCM - Regulatory Services

  • Determine compliance status of raw materials used in final food packaging globally
  • Author compliance reports to ensure safe use
  • Author and Submit required regulatory notifications to Government Authorities’ (FDA, EFSA, CFSA, etc.)
  • Supply Chain Management (ensure compliance along supply chain from raw material manufacturers to final article manufacturers)

FCM - Toxicology Support

  • Conduct risk assessments to determine safe use of FCMs

FCM - Analytical Testing

  • Work closely with partner laboratories to conduct required testing for compliance and notifications such as:
  • US 21 CFR testing, EU OML/SML testing, GB 9685 testing, etc.
  • Migration Testing

Also have a look at our complete range of FCM solutions!

You have a concern regarding food contact materials, direct/indirect food additives, food or drinking water?
We support you-contact us!

Angelique Downey
Angelique Downey
Head of Division, Food & Food Contact Materials
Dr Ioan Paraschiv
Dr Ioan Paraschiv
Senior Regulatory Affairs Manager – Food Contact Materials & REACH

Import Tolerances
& Maximum residue levels

Continuously increasing in global trade of food and feed between countries enhances the need for import tolerances (IT) as a rising number of countries are implementing regulations to control pesticide residues in imported goods by setting and enforcing maximum residue levels (MRLs) for active ingredients.

When in the importing country no national MRL exists for an agricultural commodity/active ingredient combination, the active ingredient is not registered, or the detected residues exceed the set MRL for an imported crop, then import will only be possible upon submitting petitions (dossiers) to establish import tolerances. Based on the data provided in the submitted application, an import tolerance can be set. In case the active ingredient of interest is not authorised in the importing country yet, toxicology and metabolism data have to be provided in addition to the residue data and analytical methods for enforcement purposes.

Talk with our experts about your needs for import tolerances: no matter if it is import tolerances in Taiwan, South Korea, Hong Kong, Singapore, Japan, Australia, USA, Russia, the EU or other countries, we are happy to share our knowledge.

Note: by the end of December 2021 all temporary MRLs set in South Korea will drop to 0.01 ppm. If this affects the trading of your crops you want to consider submitting import tolerance petitions to the Korean authority MFDS by March 2021 to allow for evaluation time before the full implementation of the positive list system (PLS) at the end of next year.

For support with setting of international Codex MRLs and toxicological Endpoints get in touch with our experts to discuss your JMPR submissions.



Dr Elvira Keller
Global MRL & Import Tolerance Programme Lead     

+49 621 718858 206

send email


our solutions for you

Knowing your regulatory environment is essential to stay in the market: with a global network of affiliates, knoell keeps track of the developments concerning global regulations. Read more about our strategic and regulatory consulting solutions.


  • Communication with authorities
  • Portfolio management

Document Preparation for Food Contact Materials

  • Compilation of full food contact application dossiers (petition dossiers) for authorisation in e.g. the EU (for both EU harmonised and non-harmonised FCM), United Kingdom, USA, Canada (voluntary system), MERCOSUR (= Mercado Común del Sur), China, Japan, Switzerland.
  • Preparation and review of migration testing protocols, and corresponding draft reports, for EU-harmonised FCM (i.e. plastics FCM), EU non-harmonised FCM (i.e. paper, board, printing inks, etc.) as well as other geographical areas
  • Preparation of Declaration of Compliance / Conformity (DoC) documents, based on the analysis and evaluation of targeted formulations
  • Preparation of compliance documents with respect to Good Manufacturing Practice (GMP) requirements related to the manufacturing of FCM
  • Preparation of toxicological testing protocols, and corresponding reports

Read more about our submission support services.

Preparation of Import Tolerance Petitions and Codex Dossiers

  • Dossier preparation, compilation and submission (Toxicology and Residue Dossiers)
  • Dietary exposure assessments and Risk Cup evaluations
  • Scientific statements and argumentations
  • Preparation of OECD study summaries

Food Contact Materials

  • Check of compliance status in accordance with the existing positive listing
  • Review of toxicological testing protocols and corresponding reports
  • Literature search and evaluation
  • Preparation of data gap analyses, in accordance with existing specific guidance documents, addressing all necessary data for full food contact application dossiers, including...

- Overall and specific migration data
- Worst case calculation (WCC) in the absence of migration data
- Impurity profiling, including identification and quantification of Non-Intentionally Added Substances (NIAS)
- Identification and quantification of (residual) Intentionally Added Substances (IAS) present in the final FCM or migrating into food/food simulant from the FCM
- Safety risk assessments of NIAS and non-listed IAS (where applicable) present in FCM

Import Tolerance Petitions and Codex Dossiers

  • Data gap analysis
  • Check of completeness (CoC)
  • Supporting analyses for Import and Codex MRL planning
  • Trade flow analysis (FAOSTAT, UN Comtrade)

Read more about technical and scientific support.

Study management and monitoring can be challenging tasks. Besides the various problems caused by complicated test substances, the right CRO needs to be identified for the required study and ideally you want a study to be performed in a way that it can be used for submissions in more than one country or region, if your business is international.

If you need customised study monitoring for your migration or toxicological testing or support with planning and monitoring of your residue trials, find out why knoell might be the right choice for you.

Good Manufacturing Practice (GMP) audits at the food contact materials and food contact articles manufacturing facility. That's something we can do for you, or we can support you with preparation for inspection. Further details are outlined here.

Optimise the way you perform your day-to-day work. Automation can help.

Benefit from our up-to-date expert training modules, seminars and workshops held on scheduled dates at our training premises, online or at a location of your choice and individually designed for you. Explore our knoell academy programme!

Latest News & Events on Food & Food Contact Materials

Join our talk online
online event

Sustainable Food and Non-Food Packaging

Join our talk online
12 Sep 2022
More information on
Food Contact Materials
Join our online training series
online event


Join our online training series
11 - 30 Nov 2022
More information on
Food Contact Materials

Compliance with GMP Regulations for Food Contact Materials and Food Contact Final Articles

Angelique Downey presents the most important requirements for GMP of FCM and points out the differences between EU and US regulations.