Food-Contact Testing for Baby Bottles: Migration, LFGB & Lab Reports

Food-contact testing is where compliance files are won or lost. A certificate that says “food grade” tells a retailer nothing; a migration test report for your exact material and colour, run under use conditions, tells them everything they need.

This guide explains how food-contact testing works for baby bottle materials—what overall and specific migration mean, how test conditions are chosen, what LFGB sensory testing adds, and how to read a laboratory report properly. It is general guidance, not regulatory advice.

Why Food-Contact Testing Is a Different Question

Mechanical safety testing asks whether a product can injure a child. Food-contact testing asks a different question: does the material transfer anything into the milk?

Every material—PP, PPSU, silicone, glass, and the pigments and additives inside them—can release small quantities of substances. The purpose of migration testing is to measure how much, under conditions that represent real use, and to compare it with the limits set for that substance.

Overall Migration and Specific Migration

  • Overall migration is the total quantity of all substances transferred from the material to the food simulant, expressed per unit area of material. In the EU, the overall migration limit for plastics is 10 mg/dm².
  • Specific migration looks at an individual substance—monomers, additives, colourants—and compares the measured amount with the specific limit set for that substance.

Both matter. A material can pass overall migration comfortably and still exceed the limit for one specific substance.

Test Conditions: Simulants, Time and Temperature

Because you cannot easily test with real milk over months, laboratories use food simulants and defined exposure conditions:

SimulantRepresents
WaterAqueous foods
3% acetic acidAcidic foods and drinks
10% or higher ethanolAlcoholic or fatty-aqueous mixtures
Vegetable oilFatty foods

Milk is not a single simple category, so test conditions are usually chosen to represent the worst foreseeable use—including warming and repeated use. For a reusable baby bottle, the test plan should reflect repeat-use conditions such as multiple sterilisation cycles and hot-fill or heating scenarios, not a single short contact at room temperature.

For plastics, the EN 1186 series provides the standard migration test methods used widely in Europe.

LFGB and Sensory Testing

Germany’s LFGB is a national framework that many European buyers treat as a benchmark, and it adds a requirement that is easy to overlook: sensory testing. A trained panel assesses whether the material changes the smell or taste of the food it contacts.

A product can pass chemical migration limits and still fail here. Silicone teats, flexible parts and heavily pigmented components are the usual suspects—which is why experienced buyers request sensory testing on the finished configuration, not only on raw material.

Reading a Lab Report: The Nine Things to Check

  1. Sample identification — does it name your part, material and colour?
  2. Component tested — bottle body, teat, collar, handle, decoration?
  3. Simulant used — and whether it matches your product’s real use.
  4. Exposure conditions — time and temperature, and whether repeat use was covered.
  5. Test method — the standard applied, so it can be compared with other reports.
  6. Results versus limits — a number alone means nothing without the limit beside it.
  7. Substances tested — does the panel of analysis cover the substances relevant to your market?
  8. Laboratory accreditation — is the laboratory accredited for the method?
  9. Date and scope — an old report for a discontinued colourant does not transfer to your order.

If a supplier sends a one-page “pass” sheet without these fields, ask for the full report.

The Most Common Failure Mode: Testing the Wrong Sample

Most compliance surprises are not chemistry problems—they are sampling problems:

  • Testing a natural-colour bottle, then producing it in dark grey.
  • Testing one pigment batch and shipping another.
  • Testing the bottle body but not the teat, collar or decoration.
  • Substituting a resin grade after the report was issued.
  • Reusing a report issued for another customer’s product.

Freeze the specification—resin grade, colourants and component list—before testing, and require written notification if any of it changes. See mould ownership and specification control if you are developing a custom product.

Testing Strategy by Market

MarketFrameworkTypically requested
EUFramework Regulation (EC) 1935/2004, Plastics Regulation (EU) 10/2011Declaration of Compliance, overall and specific migration reports
GermanyLFGBMigration reports plus sensory testing
United StatesFDA food-contact rules; CPSC children’s product rulesMigration or extraction testing plus CPSIA-related testing
Other marketsNational schemesVaries—build a market-by-market checklist

Frequently Asked Questions

Is BPA still allowed in food-contact materials?

BPA has been progressively restricted, and it is no longer permitted in baby bottles and sippy cups in the US. In the EU, restrictions have tightened further in recent years with transitional arrangements. Confirm the current status for your market with your compliance partner before printing any claim.

Does a raw material certificate replace migration testing?

No. A raw material declaration establishes what the material contains. Migration testing establishes what it releases under use conditions. Buyers increasingly require both.

How long are test reports valid?

Reports describe the sample tested at that time. If the material, colourant, supplier or process changes, the report should be renewed—even if no regulation has changed.

The Bottom Line

Food-contact compliance is a chain: the right material, the right colour, the right component list, tested under the right conditions, documented in a report someone else can read. Lock the specification, test the configuration you will ship, and keep the report where you can find it.

BebeFree manufactures PP, PPSU, glass and silicone feeding products in our own 8,000 m² facility and prepares material declarations and test documentation for the specific parts we produce. Request test documentation or read how EN 14350 and the EU framework apply.

Related reading: EN 14350 & CE Marking for the EU · Baby Product Safety Certifications Explained · FDA Requirements for Baby Bottles · Compliance & certifications guide

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