A food packaging product might look clean, feel sturdy, and carry a "food grade" label. But unless it has been tested at an accredited laboratory against the relevant Indian Standard, there is no objective proof that it is safe for food contact. Testing is the mechanism that converts a manufacturer's claim into verifiable compliance, and it is increasingly the first thing an FSSAI food safety officer will ask for during an inspection.
This guide explains which tests are required for different food packaging materials in India, how the testing process works, where to get testing done, what the results mean, and how to maintain a testing documentation system that satisfies regulators.
Why Testing Is Mandatory
The Food Safety and Standards (Packaging) Regulations, 2018 (Regulation 3) state that the person responsible for manufacturing or importing food contact materials shall ensure compliance with the prescribed standards. The mechanism for proving compliance is laboratory testing. The Bureau of Indian Standards (BIS) publishes the test methods, the FSSAI prescribes when testing must be conducted, and the National Accreditation Board for Testing and Calibration Laboratories (NABL) accredits the laboratories qualified to perform the tests.
Self-declaration without testing is not recognised as compliance. While enforcement historically relied on occasional sampling, the trend is toward mandatory third-party testing -- particularly for products entering organised food service chains and government procurement.
Tests Required by Material Type
Plastic Packaging (IS 9845:1998)
Plastic is the most heavily regulated material for food packaging testing. The tests required include:
| Test | What It Measures | Acceptance Criteria |
|---|---|---|
| Overall Migration (OML) | Total non-volatile substances transferring to food simulant | Not more than 60 mg/kg (or 10 mg/dm2) |
| Specific Migration -- Lead | Lead migrating from plastic to food simulant | Not more than 1 mg/kg |
| Specific Migration -- Cadmium | Cadmium migrating from plastic to food simulant | Not more than 0.002 mg/kg |
| Specific Migration -- BPA | Bisphenol A migrating from polycarbonate or epoxy-lined materials | Not more than 0.6 mg/kg |
| Colour Migration | Transfer of colouring matter from coloured plastics to food simulant | No detectable colour migration |
| Heavy Metals in Plastic | Total heavy metal content (Pb, Cd, Hg, Cr VI) in the material | Combined limit of 100 ppm |
| Residual Monomer Content | Unreacted monomers remaining in the plastic (e.g., styrene in PS, VCM in PVC) | Varies by polymer type |
For a deeper understanding of migration testing methodology, see our dedicated guide on migration testing for food packaging.
Paper and Paperboard Packaging (IS 6615)
Paper-based food packaging requires the following tests: determination of lead content (not more than 5 ppm), arsenic content (not more than 2 ppm), fluorescent whitening agent content (restricted), presence of pathogenic microorganisms (must be absent), migration of printing inks from outer surface to inner food-contact surface (no detectable migration), and tensile strength and burst strength (to ensure structural integrity under food-contact conditions).
For PE-coated or PLA-coated paper products (such as paper cups with a waterproof inner lining), both the paper base and the coating must be tested. The paper is tested against IS 6615 and the plastic coating against IS 9845.
Aluminium and Metal Packaging (IS 15495)
Aluminium foil and aluminium containers require testing for lead content (not more than 10 ppm), arsenic content (not more than 2 ppm), surface cleanliness and grease-free condition, thickness compliance (as per the declared gauge), and for lacquer-coated containers, migration from the lacquer coating to food simulants under the same conditions as plastic testing.
Glass and Ceramic Packaging (IS 2467 and IS 4853)
Glass and ceramic packaging requires lead and cadmium release testing using a standardised extraction procedure with 4% acetic acid at 22 degrees Celsius for 24 hours. The limits vary by article category. For ceramic flatware, lead release must not exceed 0.8 mg/dm2 and cadmium must not exceed 0.07 mg/dm2. For small hollowware, lead must not exceed 5.0 mg/litre and cadmium must not exceed 0.5 mg/litre.
Eco-Friendly Materials (Bagasse, Areca, Bamboo)
While no material-specific BIS standard yet exists for these materials, testing is still required under the general provisions of the FSSAI Packaging Regulations, 2018. The recommended test battery includes overall migration testing using the IS 9845 methodology, heavy metal content analysis, microbiological testing (total plate count, coliforms, E. coli, Salmonella), and chemical residue testing if chemical processing agents were used during manufacturing.
NABL-Accredited Laboratories
For a test report to carry regulatory weight, it must come from a laboratory accredited by the National Accreditation Board for Testing and Calibration Laboratories (NABL) under the quality standard ISO/IEC 17025. NABL accreditation confirms that the laboratory has the technical competence, equipment, and quality management systems to produce reliable results.
Several categories of laboratories conduct food packaging testing in India:
- BIS-recognised laboratories: Labs approved by BIS for testing against specific Indian Standards. Required for BIS certification applications.
- FSSAI-notified laboratories: Labs listed in the FSSAI notification as approved for food and food-contact testing. Approximately 270 such labs exist across India.
- Private NABL-accredited laboratories: Independent commercial labs that accept testing requests from manufacturers and buyers. These include national chains like SGS India, Bureau Veritas, TUV SUD, and Intertek, as well as regional labs.
- Indian Institute of Packaging (IIP): With centres in Mumbai, Delhi, Kolkata, Hyderabad, and Chennai, IIP offers comprehensive packaging testing services including migration testing, shelf-life studies, and material characterisation.
The Testing Process
Step 1: Sample Submission
The manufacturer or buyer submits representative samples of the packaging product to the laboratory. For migration testing, a minimum of 6 units of the finished product is typically required. The samples must be from a production batch, not prototype or pre-production samples.
Step 2: Test Method Selection
The laboratory identifies the applicable test methods based on the material type and intended use. The client specifies the food types the packaging will contact (aqueous, acidic, fatty, or all types), which determines the food simulants used in migration testing.
Step 3: Conditioning and Testing
Samples are conditioned at prescribed temperature and humidity before testing. Migration tests require contact between the packaging material and food simulants for defined durations (typically 10 days at 40 degrees Celsius for room-temperature storage applications). Heavy metal and composition tests are conducted using atomic absorption spectroscopy or inductively coupled plasma (ICP) analysis.
Step 4: Report Issuance
The laboratory issues a test report stating the test methods used, conditions applied, numerical results for each parameter, and a pass/fail determination against the applicable standard. The report carries the laboratory's NABL accreditation number and the signature of the authorised signatory.
Typical Turnaround Times and Costs
| Test Category | Typical Duration | Approximate Cost Range |
|---|---|---|
| Overall migration (single simulant) | 12-15 working days | Rs 3,000 - Rs 6,000 |
| Overall migration (all 4 simulants) | 15-20 working days | Rs 10,000 - Rs 18,000 |
| Specific migration (per substance) | 10-15 working days | Rs 2,500 - Rs 5,000 per substance |
| Heavy metal analysis (Pb, Cd, Hg, As) | 5-7 working days | Rs 3,000 - Rs 6,000 |
| Complete food-contact compliance package | 20-30 working days | Rs 15,000 - Rs 35,000 |
How Often Should Testing Be Done?
FSSAI and BIS do not prescribe a fixed testing frequency for all products. However, industry practice and regulatory expectations provide guidance. Initial testing is required when a new product is introduced or a new raw material supplier is engaged. Periodic retesting should occur at least once annually for ongoing production. Batch testing may be triggered when raw material composition changes, production process changes, customer complaints are received, or a regulator requests fresh documentation. BIS licence holders must submit annual surveillance samples as a condition of licence renewal.
Documentation Checklist for Buyers
- Migration test report (OML and SML) from NABL-accredited laboratory for every packaging product category in use
- Heavy metal analysis report for coloured or printed packaging
- BIS certification or test report referencing the applicable IS standard
- FSSAI food-contact compliance certificate from the manufacturer
- Test report date within the last 12 months (not expired)
- Test report laboratory carries valid NABL accreditation (verify on nabl-india.org)
- Reports organised by product category and supplier for quick retrieval during inspection
- Written request to supplier on file if reports were requested but not yet received
When you source packaging from a wholesale distributor like Success Marketing, the testing documentation comes with the product. We maintain current test reports for our entire food packaging product range and provide them to buyers on request.
Tested, Certified, Documented
Every product from Success Marketing comes with valid testing documentation from NABL-accredited laboratories.
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