The future of simulants in compliance testing regarding the migration from food contact materials into food

The European legislation should be amended: (i) SMLs refer to foods and, consequently, also the fat consumption reduction factor (FRF) should refer to foods exclusively (4th amendment of Directive 2002/72). (ii) The overall migration limit applies to foods (not to food or simulants, as stated in the 4th amendment of 2002/72). (iii) Simulation remains an important tool, but its relevancy must be defined more correctly. The legally specified conditions only apply if the determination in food is impossible; adjustment of simulation to migration into food has first priority, overruling the legally specified conditions in case of conflict (Directive 82/711/EEC as well as amendments 93/8/EEC and 97/48/EC). (iv) The continuous adjustment of the official testing method for simulation should be transferred to an analytically-oriented body. In conclusion, the official simulation system remains an important tool, but its legal relevance decreases with the increasing capabilities of measuring migrants in food.