Many clients pause the first time they hear "FCM testing" — this article breaks down what it actually tests and which products need it.
What FCM Testing Actually Tests
FCM (Food Contact Material) testing isn't about durability or appearance — it's about whether chemical substances in the material could migrate into food during contact. Plastic cups, stainless steel tableware, silicone baking molds, takeout containers — anything that directly touches food theoretically falls under FCM testing's scope.
Standards Differ Across the Three Major Markets
- EU: EU 10/2011 (plastics regulation) + EU 1935/2004 (general framework), focused on overall migration limits and specific substances (like BPA)
- US: FDA 21 CFR provisions, with different sections applying to different materials
- China: GB 4806 series mandatory national standards, general safety requirements plus material-specific standards
If the same product sells in all three markets, it generally needs to pass migration testing under each standard separately — one report doesn't cover all three.
Products That Often Get Overlooked
- Silicone products (many assume silicone is inherently safe, but it still requires migration testing)
- Children's tableware and baby bottles (regulatory requirements are typically stricter than adult products)
- Coated cookware (the coating itself carries different migration risk than the base material)
Frequently Asked Questions
Q: Does stainless steel tableware need testing too? A: Yes — stainless steel is mainly evaluated for heavy metal migration (nickel, chromium), a different test set than plastics, but still falls under FCM.
Q: If I've already done RoHS testing, do I still need FCM? A: No, these are different things. RoHS covers hazardous substance limits in electrical/electronic products; FCM covers migration risk in food-contact scenarios. The two systems aren't interchangeable.
If you're unsure whether your product falls under FCM testing, send us the material and intended use case for an initial assessment.