Is your client asking for a statement of compliance?
Declarations of conformity of packaging materials are issued by the company at product level as proof that these products comply with laws and regulations.
Not every finished product needs to be tested on migration. Family approaches can be used, testing every “worst case scenario”. Exactly which tests are needed depends on the conditions of use; what types of food come into contact with the packaging and under what temperature conditions and for what period of time. To make sure that migration does not increase, it has also recently become mandatory that packaging that is used repeatedly is tested 3 times for migration.
To make a declaration of compliance, migration tests on the finished product can serve as a basis, but if you know not only the identity but also the concentrations of substances in the packaging material, you can also use 100% migration calculations or possibly via modelling.
I can also assess the declarations of conformity, which you get from your suppliers, to see if they meet the requirements and request additional info where necessary.
If you receive an inspection from competent authorities, such as the Dutch NVWA or the Belgian FAVV, you need these matters to be in order.
