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This paper describes the Recycled Paperboard Technical Association (RPTA) Sampling and Analysis Protocol that RPTA member mills can use to determine that paperboard produced from recycled fibre may safely be used in food contact applications. Application of this Protocol helps to ensure compliance with the US Food and Drug Administration (FDA) regulations outlined in 21 CFR 176.260. Health risk-based allowable concentrations for potential unintended chemical constituents in the paperboard have been calculated. The protocol provides a methodology for mills to determine the concentrations of these chemicals in their paperboard for comparison with the allowable concentrations. This methodology includes guidance on what to test for, frequency of testing, sample collection methods, analytical methods and interpretation of testing results. This paper explains how and why the RPTA Protocol was developed, how it is used today, what changes have been made through the first half of 2004 and what changes may be expected in the future.

The main objective was to develop a technique to expose spots of invisible set-off of inks and lacquers on the food-contact surface of food-packaging materials. Set-off is the unintentional transfer of components of printing inks from the outer printed surface onto the food-contact surfaces. The target sensitivity was 20 microg cm(-2) and the technique should be capable of examining large areas of printed substrate for no more than 4% coverage by set-off. These requirements equate to an ability to detect a worst-case migration potential of less than 50 microg kg(-1). Other objectives were the industrial requirements that the equipment should be inexpensive, should be easy to use by existing personnel and should preferably be non-destructive with a clear criterion for pass or fail. The approaches investigated included chemical analysis of solvent extracts, Fourier-transform infrared spectroscopy and microbeam analytical techniques, but these were found to be cumbersome and had only limited success. The objectives were achieved using an optical approach to excite and observe luminescence from invisible set-off. In model experiments, resins were applied to different substrates (plastic, paper and cartonboard). For a given resin on a given material, the key to success was to maximize the discrimination between the luminescence from the resin and that from the substrate by selecting the optimal combination of exciting wavelength and viewing goggles with selective wavelength filters. The required level of detection (20 microg cm(-2)) was achieved or exceeded for all ten resins tested on three different plastics. It was also achieved for two different papers and in all but four cases of the resins on three different cartonboards. Quantitation was achieved by the use of a calibration palette prepared using different quantities of resin spotted onto the relevant blank packaging material.

A radiotracer method was applied to the measurement of inorganic contaminants migrating into food. The method was applied to the study of 10 samples of recycled paper and board. The only elements detected in the static migration test were zinc and iron, at concentrations close to the detection limit. Samples of rice, oats, custard powder, mushrooms and fries showed that traces of these elements had migrated from the packaging. The migration was limited to less than 1%, with the exception of the mushrooms, where the decomposition of the food had resulted in a 12.5% transfer of zinc from the mushroom bag after 8 days, equivalent to migration of 0.022 mg dm(-2). Shaking had no effect on migration, except in one case of custard powder where migration occurred at a level equivalent to 0.002 mg dm(-2). The maximum migration determined in the present study was 4.8 microg zinc and 2.6 microg iron, which is negligible when compared with the recommended daily intakes of 15 and 14 mg, respectively. When Tenax was tested as a food simulant, no zinc was detected (0.001 mg dm(-2)), although slight migration (0.001 mg dm(-2)) occurred into food.

The capability of a polypropylene (PP) film barrier to prevent migration of residual contaminants from recycled paperboard into food simulants was studied. Anthracene, benzophenone, methyl stearate and pentachlorophenol were chosen as chemical surrogates to represent classes of contaminants likely to be found in recycled paper/paperboard. Each surrogate was spiked into a test specimen made of seven thin virgin paper layers at concentrations of 1-50 mg kg(-1). Test specimen were dried, stacked and sandwiched with PP films, laminated with PP film and then subjected to migration experiments using a compression cell maintained at 100 degrees C for 2 h. The concentration of the surrogates in the test specimen and in 95% ethanol, isopropanol and 10% ethanol food-simulating solvents was determined by gas chromatography with flame ionization and electron capture detection. The results show that although the concentrations of the surrogates in the food simulants decreased with an increase in PP film thickness, they were still high and generally resulted in dietary concentrations >0.5 microg kg(-1), the level that US Food and Drug Administration would equate with negligible risk for a contaminant migrating from food packaging. Only at the lowest spiking level (1 mg kg(-1) benzophenone) did migration from the paperboard through a 0.127-mm PP film result in a dietary concentration of

The migration of five surrogate contaminants, anthracene, benzophenone, dimethyl phthalate, methyl stearate and pentachlorophenol, from paper and paperboard into water through a polyethylene (PE) coating layer was investigated. Virgin paper and paperboard coated with PE films of 0.012 and 0.030 mm thickness were spiked evenly with standard 1-ml solutions containing 5mg of each surrogate. The spiked papers were placed in contact with the PE coating layer at 10 and 24 degrees C for 21 days. The resulting surrogate migration through the PE layer into 100ml water was measured by an analytical method developed here that used gas chromatography equipped with a flame ionization detector. Non-polar surrogates of anthracene and methyl stearate did not show any significant migration. In the case of the thin layer coating of 0.012 mm, polar water-soluble contaminants of benzophenone, dimethyl phthalate and pentachlorophenol showed an equilibrated or maximized migration after 1 day, even at a refrigerated temperature of 10 degrees C. A thick PE coating of 0.030 mm thickness delayed the progress of contaminant migration, which was also slower at lower temperature. Our results indicate that polyethylene coatings should not be seen as a complete barrier against possible contaminants in paper packaging materials under chilled or ambient conditions. Several variables such as coating thickness, temperature and suspected contaminants need to be considered to control the possible contamination risk from recycled or printed paper.

A range of paper and board materials including carton board, corrugated board, napkins and paper towels intended for contact with food have been solvent extracted and substances present at the highest levels identified and quantified by GC/MS. Dibutyl phthalate, and diisopropylnaphthalene (DIPN) were selected to study migration to food and potential food simulants with the aim of developing a simple quick test that will give an equivalent or higher result. Tenax was found to be a suitable food simulant for dry foods and dry 'fatty foods' such as pastry and cake and was also found to be a suitable simulant for pizza base tested at higher temperatures for short contact times. The percentage migration values from corrugated and carton boards were generally in the range 15-40%, with the highest percentage being 49% for rice using conditions representing ambient storage. Quick tests were developed using Tenax under accelerated conditions of 4 h at 80 degrees C to cover room temperature storage with dry foods and fatty dry foods. These tests are suitable for compliance testing of paperboard samples if migration limits are applied in future legislation. Migration from tissues, napkins and paper towels was found to be at very low or not detectable levels, even when the levels of DIPN and DBP were significant. It is strongly suspected that this finding is due to a combination of short contact time, low grammage and the fact that the tissues absorb fat and moisture from foods, thus minimizing extraction from the paper. In all cases, the results from migration experiments into food and Tenax indicate that for the substances found at highest concentrations in the paper, currently accepted safety limits were not exceeded where they exist in EU legislation or in working documents applying to plastics.

Because of the lack of information about the possible transfer of toxic compounds from papers and boards to food, the overall cytotoxicity induced by six papers and 15 boards was investigated from water extracts prepared according to the European prestandard. Cytotoxicity measurements were based on RNA synthesis rate of human HeLa S3 cells. The tested virgin and recycled papers and boards were differentiated and classified according to their cytotoxicological quality, which ranged from absence of any cytotoxic effect to severe inhibition of RNA synthesis rate. The cytotoxicity level also varied according to the total amount of compounds detected by gas chromatography. No correlation was found between cytotoxicity and endotoxins contained in the samples. No significant difference in cytotoxicity was observed between the papers and boards produced from virgin fibres and from recycled fibres. Moreover, the products obtained from chemical pulp showed lower cytotoxicity than the products based on mechanical pulp. More generally, the cytotoxicological approach is promising for monitoring paper/board treatment-induced problems. Further work is required to assess a modified standard procedure for the preparation of water extracts specifically adapted to paper/board.

Retail samples of dry goods (bread, biscuits and breakfast cereals) packaged in waxed paper were examined for the presence of mineral hydrocarbon wax. Bread loaves contained up to 50 mg/kg of the wax (associated with the outer surfaces) and crackers up to 185 mg/kg. Mineral oil was found in bread samples, at up to 550 mg/kg and was dispersed throughout indicating its use in food processing machinery as the likely source. Retail confectionery products wrapped in waxed paper (containing 12-44% w/w) gave rise to levels of 12-1300 mg/kg mineral hydrocarbon in the individually wrapped sweets. Migration into boiled sweets was lowest at 10-130 mg/kg, whilst soft chews and toffee products contained 110-1300 mg/kg. The distribution of wax hydrocarbons (principally n-alkanes) in the confectionery coincided exactly with that for the paper wrapping, with a range of C23 to C33 (95% material) centred around C26. This indicated that the transfer to the food occurred largely by adhesion rather than by diffusion since the latter would be expected to favour preferential migration of the low molecular weight components. In simulated home-use experiments with waxed bags sold in the United States for domestic use, migration into sandwiches and cake amounted to 40 mg/kg (1% transfer of wax). Use of these waxed bags in the microwave oven (as recommended) gave rise to contamination of foods from 210 to 1650 mg/kg (up to 60% transfer of wax).

Migration of mineral hydrocarbons into dairy products and sunflower oil (fatty food simulant) has been studied using a gas chromatographic procedure. The food contact materials examined were polystyrene and ABS pots and tubs, and waxed paperboard. Levels of mineral oil in the polystyrene and ABS articles ranged from 0.3 to 5.5% w/w (13 to 366 mg/dm2) and as a coating on the paperboard ranged from 1.0 to 7.7% (55 to 565 mg/dm2). Exposure conditions were 7 days at 4 degrees C for the dairy products and 10 days at 40 degrees C for the oil. However, individual serving milk and creams (UHT) were retail samples which were stored at ambient temperature before analysis. Migration into the milk products was less than 3 mg/kg. Transfer to sunflower oil simulant and into individual serving milk products was much higher at levels up to 150 mg/kg (2 mg/dm2) and 90 mg/kg (4 mg/dm2) for the oil and milk respectively.

Bisphenol-A (BPA), dibutyl phthalate (DBP), and di-2-ethylhexyl phthalate (DEHP), which are common chemical residues in food-packaging materials, were investigated in paper and cardboard containers used for take-away food. The oestrogenicity of aqueous extracts was tested in E-Screen bioassay and analysis carried out by high-performance liquid chromatography (HPLC) and gas chromatography-mass spectrometry (GC/MS). Oestrogenicity was demonstrated in 90% of extracts (geometric mean [GM] = 11.97 pM oestradiol equivalents g(-1)). DEHP, DBP, and BPA (GM = 341.74, 37.59, and 2.38 ng g(-1) of material) were present in 77.50, 67.50, and 47.50% of samples, respectively. In bivariate analyses, no significant association was found between the levels of these chemicals and oestrogenicity in cardboard/paper extracts. A close-to-significant association was found between oestrogenicity and DBP (beta = 1.25; p = 0.06) in paper extracts, which reached statistical significance in multivariate analysis (beta = 1.61; p = 0.03). Paper and cardboard used in food packaging may contribute to the inadvertent exposure of consumers to endocrine-disrupting chemicals.

There are many initiatives in Europe trying to refine the exposure assessment for food packaging migrants. In the USA, the US Food and Drug Administration (US FDA) uses food consumption and food-type distribution factors to aid the exposure assessment process and generate more realistic estimates of exposure. The present study developed food-consumption factors and food-type distribution factors for Irish children aged 5-12 years from data collected as part of a National Children's Food Survey (NCFS) completed in Ireland in 2003-04, combined with data from the 2003-05 Irish Food Packaging Database and from literature data on surface area-to-weight ratios for food packaging. Consumption factors are defined as the fraction of a person's diet likely to contact a specific food-contact material, while food-type distribution factors reflect the fraction of all food contacting each material that is aqueous, acidic, alcoholic or fatty. In this study, it was found that 'total plastics' had the highest consumption factor of 0.83, while 'total paper and board' had a factor of 0.13 and 'total metal and alloys' had a factor of 0.06. Although it is tentative to compare the US FDA factors with the factors derived in the current study, as the US FDA data are for the total US population, the consumption factor for 'total plastics' in the present study (0.83) was similar to that used by the US FDA (0.79). However, a large difference existed for the consumption factor for 'total metal and alloys' in the Irish data (0.06) and the US FDA data (0.2). In terms of the type of materials used for foods, glass was used mainly for acidic foods (0.67), while plastic was uniformly used for all food types. The food-contact area for plastic packaging for all foods consumed by children was 10.67 dm2/child day(-1), which is slightly lower than the proposed value for the average European consumer of 12.4 dm2/person day(-1). However, this should be expected, as children do not consume as much food as adults. When scenario exposure estimates were made, it was found that when using European Union assumptions, estimates were much larger than when using consumption factors and food-type distribution factors in the exposure assessment, even when conservative assumptions were employed for the consumption factor. This study highlights the potential use of consumption factors and food-type distribution factors in the refinement of the exposure assessment process and how these factors can be calculated using data collected as part of a national food survey.

An investigation was undertaken to establish the concentration in paper products of dehydroabietic (DHA) and abietic (AA) resin acids, present in rosin, which are major toxicants of pulp- and paper-mill effluent. Their migration was studied from paper and paperboard products into various food-simulating solvents and the substitute fatty food simulant Tenax TA (modified polyphenylene oxide). DHA and AA were detected in five of 10 virgin paper products and in all 10 recycled paperboard products for food-contact use at concentrations of 14-500 and 110-1200 microg/g, respectively. In virgin paper products, the highest migration was into 95% ethanol or heptane, with negligible or no migration into other solvents. In recycled paperboard products, migration was highest into 95% ethanol, but was also observed into 20% ethanol, water and heptane. Migration to Tenax TA was also observed and the migration level increased with time. The maximum migration levels of DHA and AA into food simulants were 0.853 and 3.14 microg/g, respectively. The results suggest that, in the worst case, the daily intake of DHA and AA from paper and paperboard products was 50 times lower than the tolerable daily intake of rosin.

In the European Union (EU), many assumptions are employed to calculate the intake of migrating chemicals from food packaging. However, very little is known about the actual intake of packaged food, the type of this food and the type of packaging used for this food. The objective of the current study was to examine intakes of packaged food in children aged 5-12 years to provide information on the types of food that are packaged and the type of packaging used. To do this, a food-consumption database, which also recorded information on packaging, was merged with a packaging database, which provided information on the contact layers of packaging. Foods were classified into EU Food categories according to European Council Directive EC 85/575/EEC (European Council 1985), which determined their food type (i.e. aqueous, acidic, alcoholic and fatty). The mean daily intake of all packaged food was 1195 g day-1 with an upper intake of 1959 g day-1 (97.5th percentile); the intake of food packaged in plastic was 993 g day-1 with an upper percentile of 1692 g day-1 (97.5th percentile). The mean daily intake of fat from all packaged food was 62 g day-1, with an upper intake of 100 g day-1 (97.5th percentile). When this was investigated further, it was found that the mean fat intake from packaged 'fatty' foods only was 32 g day-1, with an upper intake of 61 g day-1 (97.5th percentile). The food that contributed most to fat intake was milk. As many food chemical intake assessments are moving towards probabilistic methods, probabilities of a food being packaged and the probability of the type of packaging used were determined. The probability of food being packaged was 0.88. Some foods not 100% packaged included fruit, vegetables, liquid beverages non-alcoholic (includes water) and bread. Probabilities were also derived for the packaging types used for food. It can be concluded that not all the individual assumptions used in the EU exposure assessment are conservative, but in combination they are conservative.

Contamination of foods with trimethyldiphenylmethanes is reported and the origin is shown to be migration from food packaging materials of which the use of recycled carbonless copy paper was found to be the major source. This chemical is one of the solvents used in the carbonless copy paper and its presence in food and the environment has not been previously identified. In this paper we have pursued previous studies on diisopropylnaphthalenes and hydrogenated terphenyls contamination from packaging and now report the identification of this new food contaminant and present evidence of its source. Solid foods such as egg pasta, barley coffee and rice were analysed by GC/MS and a mean concentration of 18 microg/kg of trimethyldiphenylmethanes was found. Extracts from carbonless copy paper were analysed by proton NMR to characterize the trimethyldiphenylmethanes. Since trimethyldiphenylmethanes are found in solid food together with diisopropylnaphthalenes, and considering their similar chemical character, they may follow the same migration pathway as one another.

Perfluorochemicals are widely used in the manufacturing and processing of a vast array of consumer goods, including electrical wiring, clothing, household and automotive products. Furthermore, relatively small quantities of perfluorochemicals are also used in the manufacturing of food-contact substances that represent potential sources of oral exposure to these chemicals. The most recognizable products to consumers are the uses of perfluorochemicals in non-stick coatings (polytetrafluoroethylene (PTFE)) for cookware and also their use in paper coatings for oil and moisture resistance. Recent epidemiology studies have demonstrated the presence of two particular perfluorochemicals, perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) in human serum at very low part per billion levels. These perfluorochemicals are biopersistent and are the subject of numerous studies investigating the many possible sources of human exposure. Among the various uses of these two chemicals, PFOS is a residual impurity in some paper coatings used for food contact and PFOA is a processing aid in the manufacture of PTFE used for many purposes including non-stick cookware. Little information is available on the types of perfluorochemicals that have the potential to migrate from perfluoro coatings into food. One obstacle to studying migration is the difficulty in measuring perfluorochemicals by routine conventional analytical techniques such as GC/MS or LC-UV. Many perfluorochemicals used in food-contact substances are not detectable by these conventional methods. As liquid chromatography-mass spectrometry (LC/MS) develops into a routine analytical technique, potential migrants from perfluoro coatings can be more easily characterized. In this paper, data will be presented on the types of perfluoro chemicals that are used in food packaging and cookware. Additionally, research will be presented on the migration or potential for migration of these chemicals into foods or food simulating liquids. Results from migration tests show mg kg(-1) amounts of perfluoro paper additives/coatings transfer to food oil. Analysis of PTFE cookware shows residual amounts of PFOA in the low microg kg(-1) range. PFOA is present in microwave popcorn bag paper at amounts as high as 300 microg kg(-1).

In order to identify potential genotoxicant(s) in recycled paperboard, samples were fractionated using multiple liquid/liquid extraction, and gel permeation chromatography, and analysed by gas chromatography/mass spectrometry and liquid chromatography/mass spectrometry. The rec-assay was used as an indicator of genotoxicity. Genotoxicants in the recycled paperboard were identified as dehydroabietic acid (DHA) and abietic acid (AA). DHA and AA were detected in two out of five virgin products, and in all seven recycled products for food-contact use. Total amounts of DHA and AA were 240 and 990 microg/g in the virgin products and 200-990 microg/g in the recycled products. A good correlation was observed in the total amount of DHA and AA content determined in paper products and DNA-damaging activity. Moreover, genotoxic effects in paper products showed a good match with standard compounds, indicating that the genotoxic effects of these paper products was mostly attributable to DHA and AA.

Packaging samples for many kinds of foodstuffs were received from manufacturers together with basic information about the materials used in their production. Half of the 29 samples studied contained phthalates in amounts exceeding 5 mg/kg. Two types of paper bag intended for sugar and exceptionally high phthalate contents although they were flexo printed. The maximum contents of di-isobutylphthalate (DIBP) and dibutylphthalate (DBP) were 450 and 200 mg/kg, respectively. The phthalates found originated from adhesives used in the joints of the packaging. In other packagings manufactured at the same time, DIBP concentrations varied from 92 to 193 mg/kg. Phthalates were also determined in sugar before and after packaging. Migration of phthalates ranged from 57 to 74% of the original content in the packaging after 4 months storage. Packed sugar contained DIBP 2.2-2.6 mg/kg and DBP 0.5-1 mg/kg. The sugar packagings were also tested using Tenax as a food stimulant. The results indicated that 69-91% of the original content of the phthalates migrated into Tenex after 10 days at 40 degrees C. The major drawback with migration testing using Tenax is its high cost; it is not practical to fill the whole 1 kg packaging with Tenax, and smaller samples of packaging must be used instead. However, the distribution of substances in the packaging might be non-uniform. In the sugar packagings studied here, the difference between phthalate concentrations in two samples taken from the same packaging was nearly 100-fold.

The results of a study of the potential migration of diisopropyl naphthalenes (DIPN) from recycled paperboard packaging into some types of dry solid foodstuffs are reported. Paperboard diskettes containing different DIPN concentrations were prepared and put into contact with four types of dry solid foodstuffs, having high specific surface areas and different lipid contents. At regular intervals the DIPN content in the foods was determined. Two migration mechanisms have been proposed and verified. The first one relates to the direct contact existing between paperboard and foodstuff. The second one refers to the indirect contact between paperboard and food, controlled by an air space created above the paperboard into which the DIPN has diffused. Both mechanisms occurred and the migration depended on different factors: the contact time, the characteristics of the foodstuffs and the DIPN content in the cellulose-based matrix. However, only very low levels of contamination in the foodstuffs occurred in migration. As a consequence, this report also considers possible limitations which could be applied to the content of carbonless copy paper in packaging paperboard formulations.

The sensory and chemical shelf-life of UHT-milk stored at room temperature and at 6 degrees C in aluminium-foil, non-foil barrier (X-board) and PE cartons were investigated. UHT milk in aluminium-foil stored in the dark has a minimum shelf-life of 6 months, while the shelf-life is 4-5 months in X-board and PE cartons. When PE cartons and X-board cartons are stored with strong light exposure at 6 degrees C, a development of light-induced off-flavour is detected after 2 and 8 weeks, respectively. The light-induced off-flavour effect is more pronounced than the effect of non-light induced oxidation of unsaturated lipids.

A survey of 32 paper and board materials intended for food contact has been undertaken. Sample composition was analysed to identify chemicals with a potential to migrate to foods. Representative materials covering a range of uses such as aqueous and fatty foods, and use at ambient and elevated temperatures, were obtained from industry. The samples were examined in their unfinished state, even where the final form would have included lamination to plastics, printing, or other treatments. A comprehensive and systematic analytical approach was applied which included determination of volatiles by headspace GC-MS, extraction using water, ethanol and chloroform with subsequent analysis by GC-MS and HPLC, and multi-element screening by ICP-MS. The solvent extracts were also weighed to determine the total amount of material available for migration. A large number of volatile substances were identified with alkyl and aryl aldehydes predominating in the majority of samples. Substances identified in solvent extracts included 2,6-di-tert-butyl-4-hydroxytoluene (BHT), di-tert-butylphenol, benzophenone, 4,4'-bis(dimethyl amino) benzophenone (Michler's ketone), triphenyl methane, bicyclohexylphenylphenanthrene carboxylic acid (and its methyl ester) and abietic acid. Levels of these substances were however generally below 1 mg/kg paper. Of the inorganic elements, arsenic and mercury were not detected above the limits of determination of 1.8 and 0.4 mg/kg respectively in any of the 10 samples examined. Cadmium was detected in teabag tissue and in unbleached Kraft paper at 0.3 mg/kg. Chromium was present in seven samples at 1.1-7.8 mg/kg, whilst lead was present in nine of the 10 samples at levels ranging from 0.3 to 5.9 mg/kg.

A survey of retail samples was conducted in two phases with 50 general paper and board food contact materials and articles analysed in 1992, and 121 samples, specifically of printed cartonboard, analysed in 1995. Packaging samples were extracted with ethanol containing 0.4% triethylamine. The extracts were analysed using high performance liquid chromatography (HPLC) and the presence of 4,4'-bis (dimethylamino) benzophenone (Michler's ketone, MK) and 4,4'-bis (diethylamino)-benzophenone (DEAB) confirmed using gas chromatography coupled to mass spectroscopy (GC-MS). The limits of detection for MK and DEAB in packaging were 0.05 mg/kg and 0.1-0.2 mg/kg respectively. In the first phase, MK was detected in 24% of the 50 samples at concentrations of 0.06-3.9 mg/kg paper. DEAB was detected in 12% of samples (0.1-0.2 mg/kg). In the second phase, 26% of the 121 cartonboard samples contained detectable MK (0.1-1.6 mg/kg) and 4% contained DEAB (0.2-0.7 mg/kg). Residues of the monoamine 4-(dimethylamino)benzophenone (DMAB) were found in 10% of the 1992 samples (0.1-0.6 mg/ kg). DMAB was not surveyed in 1995. These levels are too low to indicate the use of these cure agents for printing the packages. Rather, the most likely origin is from the use of recycled fibres. For three samples where the highest concentration of MK was detected, the food was analysed by GC-MS after extraction and clean-up. There was no measurable migration of MK at a detection limit of 2 micrograms/kg food. It is concluded, therefore, that the concentrations of MK present in the packaging samples analysed are unlikely to pose a risk to human health.

The predicted migration test requirements for food and beverage cans with internal lacquer coatings and plastics paperboard composites against future EC legislation, are described. In a project currently in hand at Pira International on behalf of the UK Ministry of Agriculture, Fisheries and Food, some of the problems which arise when migration testing food and beverage cans with the food simulant 3% (w/v) acetic acid solution are being investigated. The 3% (w/v) acetic acid simulant has a tendency to penetrate the lacquer coating resulting in corrosion of the metal substrate. Experiments in hand and planned on this problem, with some of the initial results, are presented. There are also problems with overall migration testing of food packaging consisting of plastics paperboard composites with the fatty food simulant (olive oil). With one particular problem there is at present no obvious answer.