How Food pH, Fat and Temperature Set GCC Migration Test Conditions (2026)
PhD, FRSC · Head of Regulatory Affairs & Nutrition Science, Food Research Lab
✓ Technically reviewed by the FRL Formulation & Regulatory Panel · Last reviewed: 23 October 2026 · Next review: April 2027
23 October 2026
Last checked
23 October 2026
Reading time
13 min
Sources
15
- The food sets the test: pH, fat and filling or serving temperature decide the simulant and the worst-case time and temperature.
- Under EU Regulation 10/2011, foods below pH 4.5 take 3% acetic acid (B); oil-in-water emulsions take 50% ethanol (D1); foods with free surface fat take vegetable oil (D2).
- GSO 1863/2013 closely tracked the EU plastics rules, with an overall migration limit below 10 mg/dm² or 60 mg/kg; confirm the 2021 edition and national adoption for each market.
- Assigned simulants can under-represent complex fatty foods: Caesar dressing, tahini and mayonnaise all scored RED above 1 against D2 in a 2026 model study.
- Lower fill temperature and shorter contact are among the strongest levers; pH is usually fixed by food safety.
Introduction
Packaging does not pass or fail in the abstract. A migration test judges it against a specific food, at a specific temperature, for a specific time, so the test conditions start with the food itself: its pH, its fat content and how hot it is filled, served or reheated. For brands exporting to Saudi Arabia, the UAE and the wider Gulf, this matters twice over. Gulf (GSO) standards have legal effect only once member states adopt them into national law,[1] and the EU plastics rules that the Gulf plastics standard has closely tracked were amended again in 2025.[2]
This explainer covers plastic food-contact materials and the migration testing that proves them. For paper packaging and PFAS, read our guide to PFAS-free paper packaging rules in the GCC. For oil moving through paper, rather than substances moving into food, see our review of fat migration in PFAS-free paper packaging.
Why pH, Fat and Temperature Decide Migration Test Conditions
How food type maps to a food simulant
A food simulant is a test medium that stands in for real food. Under Regulation (EU) No 10/2011, simulants A (10% ethanol), B (3% acetic acid) and C (20% ethanol) are assigned to foods with a hydrophilic character. B is used for foods with a pH below 4.5, and C for alcoholic foods up to 20% alcohol and for foods with enough organic ingredients to make them more lipophilic. D1 (50% ethanol) covers alcoholic foods above 20% and oil-in-water emulsions, D2 (vegetable oil) covers foods with free fat at the surface, and E, a polymer sorbent, is used for specific migration into dry foods.[3] The logic behind the scheme is the old rule that like dissolves like.[4]
Table 1. Food simulants under Regulation (EU) No 10/2011, with the example foods used in a 2026 solubility study
| Simulant | Composition | Assigned to (Annex III) | Example foods in the 2026 study |
|---|---|---|---|
| A | Ethanol 10% (v/v) | Hydrophilic foods | Honey, almond butter, mayonnaise |
| B | Acetic acid 3% (w/v) | Hydrophilic foods with a pH below 4.5 | Vinegar, yogurt, pesto sauce |
| C | Ethanol 20% (v/v) | Alcoholic foods up to 20% alcohol; foods whose organic ingredients make them more lipophilic | Aperitif (11%), orange juice, apricot marmalade |
| D1 | Ethanol 50% (v/v) | Alcoholic foods above 20% alcohol; oil-in-water emulsions | Whiskey, milk, cottage cheese |
| D2 | Vegetable oil | Foods with free fat at the surface | Caesar dressing, tahini, mayonnaise |
| E | Poly(2,6-diphenyl-p-phenylene oxide) sorbent | Specific migration into dry foods | Not studied |
Sources: assignments from Annex III of Regulation (EU) No 10/2011;[3] example foods as assigned by Agolli et al.[4] Several foods carry two simulants (the study tested mayonnaise against A and D2), so check Annex III, Table 2 for your exact food category.
Why acidity and fat are the key variables
Acidic and fatty foods tend to pull more out of plastic packaging. A 2025 systematic review of 67 studies (5,378 samples) found that phthalates and bisphenols consistently migrated from plastic packaging into food. Temperature, exposure time and food composition shaped the result, with high-fat or acidic foods giving higher migration; too few PFAS studies existed to draw conclusions.[5] Behind this sits transport physics. Migration is governed by diffusion, which sets how fast a substance moves through the polymer, and by partition, which sets how it distributes between the polymer and the food at equilibrium.[6]
Setting Migration Test Conditions in the GCC
What the Gulf texts cover
Three Gulf instruments frame food-contact plastics. GSO 2231:2012 covers all materials and articles intended to come into contact with food,[7] GSO 839:2021 sets general requirements for food packages (Part 1),[8] and GSO 1863:2021 sets general requirements for plastic packages (Part 2).[9] Saudi Arabia’s SFDA lists SFDA.FD/GSO 839 and SFDA.FD/GSO 1863 as its food-packaging requirements.[10] In the UAE, food-contact materials are certified under MoIAT’s conformity scheme, and our GCC food-contact guide lists the documents it requires.
The earlier edition, GSO 1863/2013, closely tracked the structure of Regulation (EU) No 10/2011. Its positive list of 885 substances corresponded to the first 885 substances in the EU list, and plastic packages in direct contact with food had to meet an overall migration limit of less than 10 mg/dm² or 60 mg/kg.[1] We have not reviewed the full text of the paid 2021 edition, so confirm its limits and any test conditions against the purchased standard. A 2018 legal review also found that national adoption varied, although GSO 1863/2013 was reported as mandatory in all six GCC states.[1] There is therefore no single GCC-wide migration test. Where a Gulf text does not specify simulants, times and temperatures, the laboratory report should state which method it followed and why; given how closely GSO 1863 has tracked the EU plastics rules, those rules are the natural reference.
EU limits used as the reference
Two limits frame every result. The overall migration limit caps the total constituents a material transfers: 10 mg per dm² of food-contact surface, or 60 mg per kg of food simulant for materials intended for food for infants and young children.[3] Each specific migration limit (SML) caps one listed substance.[3] Plastics made with recycled content are also covered by Regulation (EU) 2022/1616,[11] and Regulation (EU) 2025/351 amended both regulations in 2025, adding purity requirements for substances used in plastics and revising the Declaration of Compliance.[2]
Choosing time and temperature for worst-case contact
Test conditions should cover the most severe foreseeable use of the pack: hot-fill, reheating and the longest storage. For overall migration, Regulation 10/2011 sets standardised tests that run from 10 days at 20 °C for frozen or chilled food to 2 hours at 175 °C for high-temperature use with fatty foods (Table 2).[3] A fatty food served hot is therefore tested harder than the same food served chilled.
Table 2. Standardised overall migration tests in Regulation (EU) No 10/2011 (Annex V, paraphrased)
| Test | Time and temperature | Intended contact conditions |
|---|---|---|
| OM1 | 10 days at 20 °C | Any contact with frozen or refrigerated food |
| OM2 | 10 days at 40 °C | Long-term storage at room temperature or below, including brief heating |
| OM3 | 2 h at 70 °C | Brief heating not followed by long-term room-temperature or chilled storage |
| OM4 | 1 h at 100 °C | High-temperature use up to 100 °C with all food simulants |
| OM5 | 2 h at 100 °C or reflux, or 1 h at 121 °C | High-temperature use up to 121 °C |
| OM6 | 4 h at 100 °C or reflux | Contact above 40 °C for foods assigned to simulants A, B or C |
| OM7 | 2 h at 175 °C | High-temperature use with fatty foods beyond OM5 conditions |
Source: Regulation (EU) No 10/2011, Annex V.[3] Read the full conditions and exceptions in the official text before choosing a test.
Two correction factors can reduce a measured result, and neither applies by default. Where Annex III gives a figure next to D2 for a food category, the D2 result is divided by that figure. Separately, the fat reduction factor (FRF) corrects the specific migration of listed lipophilic substances into foods with more than 20% fat; it does not apply to food for infants and young children, and the two corrections combined cannot exceed a factor of 5.[3] Simulants can also over- or under-state migration for a given food,[4] so any correction needs data behind it.
How Food pH Changes Migration
Acidity changes how aggressively a food extracts additives, which is why 3% acetic acid is the simulant for foods below pH 4.5.[3] The 2025 review links acidic foods to higher phthalate and bisphenol migration.[5] A 2026 Hansen solubility parameter study supports simulant B for simple acidic liquids: yogurt and vinegar matched it closely, with a relative energy difference (RED) of 0.02 and 0.04, where values below 1 suggest compatibility. Pesto sauce, an acidic food that contains oil, scored 0.90 ± 0.34, and the authors grouped it with the six poorly matched food–simulant pairs.[4] Once oil enters the matrix, pH rarely acts alone.
How Fat Content Changes Migration
Fat is the harder variable, because lipophilic additives, oligomers and stabilisers dissolve readily into oil. In a study of polypropylene microwavable containers from 21 brands sold in the Philippines, 88.9% of the analysed samples released more UV-absorbing contaminants into n-heptane, a fatty-food simulant, than into water or 20% ethanol. No sample exceeded the national limit in water or 20% ethanol, but exceedances occurred in n-heptane.[12]
With plasticised polylactic acid (PLA), swelling and migration were negligible in 10% ethanol, yet the EU specific migration limits were exceeded in 50% ethanol (simulant D1) for all three stabilisers studied.[13]
Simulants can also miss what a fatty food would extract. In the 2026 solubility study, Caesar dressing, tahini and mayonnaise, all assigned to D2, had RED values above 1 (1.46, 1.03 and 1.04). The authors also counted almond butter (0.99) and mayonnaise (1.15) tested with simulant A among the poorly matched pairs. For Caesar dressing, migration was predicted to be underestimated for an average of about 58% of the migrants chemically related to the food.[4] These are model predictions from nutritional composition, supported by experiments on mayonnaise, not measured migration results.[4]
How Temperature and Contact Time Change Migration
Heat speeds diffusion and swells polymers, so time and temperature are decisive. In one polypropylene container, contaminant migration into n-heptane correlated strongly with contact time (R = 0.975 over 15–120 minutes) and with temperature (R = 0.856 over 0–66 °C).[12] In a 2025 study of water held in polypropylene and general-purpose polystyrene cups and containers, no endocrine-disrupting chemicals were found at 4–10 °C. At 40–100 °C, phthalates, bisphenol A and nonylphenol were released from polypropylene, and polypropylene released significantly more on average than polystyrene.[14] A 2022 kinetics study found that the effect of temperature on stabiliser migration from polypropylene and PLA apparently exceeded that of plasticiser content,[15] so a lower fill or serving temperature is among the most effective levers.
What Formulation Science Can Change to Lower Migration Risk
Adjusting pH, fat and processing conditions
Because the test conditions derive from the food, changing the food or its process can change the test.
- Characterise the real matrix. Measure pH, fat, alcohol and water activity, and check whether the assigned simulant represents the product. Solubility modelling suggests a food-specific simulant could be identified where it does not.[4]
- Moderate fill temperature and contact time where the process allows, since both drive migration.[12][15] A lower maximum temperature can also move the product to a milder standardised test.[3]
- Reduce free oil at the pack wall. Lipophilic migrants partition into fat, so less free oil at the contact surface should lower the driving force. This is an inference; confirm it by testing.
- Treat pH as safety-bound. pH is usually set by microbiological safety, so change it for migration only where safety margins allow.
Packaging, barrier and material choices
Material choices carry equal weight. Plasticiser content enhanced swelling and additive migration from polypropylene and PLA,[15] and in PLA, plasticisation raised migration only when the simulant swelled the plastic, from 20% ethanol upward.[13] When hot, polypropylene released more endocrine-disrupting chemicals than polystyrene.[14] A 2024 review lists barrier coatings, appropriate material selection and optimised storage conditions among the ways manufacturers reduce migration risk.[6] Pack and recipe decisions belong together in food product development.
Formulator’s note: define the worst case first, then reformulate
Fix the true pH, fat level and fill temperature, then set the migration test conditions the product will impose. A pass in simulant A on a high-oil dressing may not reflect real migration, so test with the food itself or justify the simulant with data. Record the exact simulant, time and temperature in the dossier.
Practical Testing and Compliance Checklist
- Profile the food: record pH, fat, alcohol, water activity, fill temperature, reheating instructions and shelf life.
- Assign the simulant: match the food to simulants A–E using Annex III of Regulation 10/2011, and flag emulsions, dressings and nut pastes where the simulant may mislead.[3][4]
- Set worst-case conditions: choose the test that covers hot-fill, reheating and the longest foreseeable storage.[3]
- Test overall and specific migration: check the overall migration limit and every applicable specific migration limit, and screen for non-intentionally added substances.
- Compile the dossier: assemble the Declaration of Compliance, the GCC conformity documents for each target market and test reports that state the simulant, time and temperature.[2][10]
Conclusion
A food’s pH, fat content and serving temperature decide which simulant and which time–temperature test its packaging must pass, and the same properties show where formulation can help. Gulf plastics rules have closely tracked the EU scheme, but national adoption and the current GSO texts still need checking for each market. Document the real food, justify the simulant, moderate heat and time where the process allows, and choose lower-migration contact layers, so that migration testing confirms compliance rather than uncovering problems late.
For Brands & Formulators: Setting Migration Test Conditions for GCC Export
If you are preparing a packed food for Saudi Arabia, the UAE or the wider GCC, FRL’s scientific and regulatory research team can map your product to the right simulants and worst-case test conditions before you commission testing.
- Map the food: pH, fat, alcohol, fill and serving temperature, reheating and shelf life.
- Set the test plan: simulants, overall migration test and specific migration checks, with the reasoning recorded for the dossier.
- Check the documents: review supplier declarations and test reports against GSO 2231, GSO 839, GSO 1863 and the EU reference rules, and list the gaps.
For pack-level testing, see our packaging industry services, or contact the team to scope the work.
- ✓Profile each SKU: pH, fat, alcohol, water activity, fill and serving temperature, reheating and shelf life.
- ✓Assign and justify the simulant from Annex III of Regulation 10/2011, flagging emulsions, dressings and nut pastes.
- ✓Pick the worst-case test that covers hot-fill, reheating and the longest storage.
- ✓Confirm the Gulf texts (GSO 2231, GSO 839, GSO 1863:2021) and national requirements for each target market.
- ✓Get a test plan reviewed by FRL’s scientific and regulatory research team.
How do pH, fat and temperature set migration test conditions?
They decide which food simulant and which time–temperature test represent the real product, because acidic, fatty and hot-served foods extract more from packaging.[5] Under the EU rules, foods below pH 4.5 use 3% acetic acid, oil-in-water emulsions use 50% ethanol and foods with free surface fat use vegetable oil; the hotter or longer the foreseeable contact, the harsher the test.[3]
What food simulants are used in migration testing?
Regulation (EU) No 10/2011 uses A (10% ethanol), B (3% acetic acid), C (20% ethanol), D1 (50% ethanol), D2 (vegetable oil) and E (a polymer sorbent for specific migration into dry foods).[3] GSO 1863 has closely tracked this regulation,[1] but Gulf requirements bind only as adopted nationally, so confirm the current text for each market.
Can formulation changes lower migration risk?
Yes, within safety limits. Lowering fill or serving temperature and shortening contact reduce migration,[12][15] and a lower-plasticiser or barrier-protected contact layer can help.[6][15] Limiting free oil at the pack wall should lower the driving force for fat-soluble migrants, but test it. pH is usually fixed by microbiological safety, so change it only where safety margins allow.
What are overall and specific migration limits?
The overall migration limit caps the total constituents a material transfers: 10 mg/dm² of contact surface in the EU, or 60 mg/kg of food simulant for materials for infants and young children. Specific migration limits cap individual listed substances.[3] GSO 1863/2013 set an overall limit of less than 10 mg/dm² or 60 mg/kg.[1]
Is there a single GCC-wide migration test?
- Skaggs, K. C., & Misko, G. G. (2018). The regulation of food-contact materials in the Middle East. PackagingLaw.com, Keller and Heckman LLP. https://www.packaginglaw.com/special-focus/regulation-food-contact-materials-middle-east (cited for national adoption of GSO standards and the GSO 1863/2013 overall migration limit and EU-based substance list)
- European Commission. (2025). Commission Regulation (EU) 2025/351 of 21 February 2025 amending Regulation (EU) No 10/2011, Regulation (EU) 2022/1616 and Regulation (EC) No 2023/2006 as regards recycled plastic and other matters related to quality control and manufacturing of plastic food-contact materials. Official Journal of the European Union, L, 2025/351. https://eur-lex.europa.eu/eli/reg/2025/351/oj (cited for the 2025 amendments: purity requirements and the Declaration of Compliance)
- European Commission. (2011). Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food. Official Journal of the European Union, L 12, 1–89. https://eur-lex.europa.eu/eli/reg/2011/10/oj (cited for simulant assignment, overall migration limits, standardised test conditions and correction factors)
- Agolli, E., Moustafa, C. A., Almpani, A., Anagnostopoulou, C., Aslanidou, M.-A., Bapka, A., Chaziri, E., Cvetkovic, A., Dalkalitsi, E., Dekaltsidou, D.-C., Diamantopoulou, A., Dragoti, K., Foura, K., Goltsiou, S., Hatziioannou, P., Ilia, D., Kaloudi, S., Karaoulanis, C., Karetsa, A., . . . Tsioptsias, C. (2026). A Hansen solubility parameter study on the suitability of EU food simulants for migration testing. Journal of the Association of Greek Chemists. https://doi.org/10.62579/JAGC0019 (cited for food–simulant RED values and predicted underestimation of migration)
- Tanzer, M., Boissiere-O’Neill, T., Sly, P. D., & Vilcins, D. (2025). Phthalates, bisphenols and per- and polyfluoroalkyl substances migration from food packaging into food: A systematic review. Reviews on Environmental Health, 40(3), 616–625. https://doi.org/10.1515/reveh-2025-0027 (cited for higher migration into high-fat and acidic foods)
- Gupta, R. K., Pipliya, S., Karunanithi, S., Eswaran U, G. M., Kumar, S., Mandliya, S., Srivastav, P. P., Suthar, T., Shaikh, A. M., Harsányi, E., & Kovács, B. (2024). Migration of chemical compounds from packaging materials into packaged foods: Interaction, mechanism, assessment, and regulations. Foods, 13(19), Article 3125. https://doi.org/10.3390/foods13193125 (cited for diffusion and partition mechanisms and mitigation strategies)
- GCC Standardization Organization. (2012). General requirements for the materials intended to come into contact with food (GSO 2231:2012) [Gulf technical regulation]. https://www.gso.org.sa/store/standards/GSO:589298/GSO%202231:2012?lang=en (cited for scope: all food-contact materials)
- GCC Standardization Organization. (2021). Food packages: Part 1: General requirements (GSO 839:2021, 2nd ed.) [Gulf technical regulation]. https://www.gso.org.sa/store/standards/GSO:780890/GSO%20839:2021?lang=en (cited for scope: general requirements for food packages)
- GCC Standardization Organization. (2021). Food packages: Part 2: Plastic package: General requirements (GSO 1863:2021) [Gulf technical regulation]. https://www.gso.org.sa/store/standards/GSO:780896/GSO%201863:2021?lang=en (cited for the current edition of the Gulf plastic-packaging standard)
- Saudi Food and Drug Authority. (2024). What are the requirements of food product packaging? [FAQ]. https://www.sfda.gov.sa/en/faq/88889 (cited for SFDA.FD/GSO 839 and SFDA.FD/GSO 1863 as Saudi packaging requirements)
- European Commission. (2022). Commission Regulation (EU) 2022/1616 of 15 September 2022 on recycled plastic materials and articles intended to come into contact with foods, and repealing Regulation (EC) No 282/2008. Official Journal of the European Union, L 243, 3–46. https://eur-lex.europa.eu/eli/reg/2022/1616/oj (cited for EU rules on recycled plastic food-contact materials)
- Encarnacion, E. K. P., Pukunum, S. M. J. M., Mantile, M. J. F., Mendoza, J. A. T., Ting, R. M. S. M., Alcantara, A. C., Alejandro, W. P., Del Rosario, A. F., & Alcarde, D. J., Jr. (2026). Migration of total UV-absorbing contaminants from Philippine polypropylene microwavable containers: Effects of food simulant, contact time, and temperature. Acta IMEKO, 15(2), 1–8. https://doi.org/10.21014/actaimeko.v15i2.2298 (cited for higher migration into n-heptane and the time and temperature correlations)
- Dragan, V. K., Petrovics, N., Kirchkeszner, C., Tábi, T., Szabó, B. S., & Eke, Z. (2024). The kinetics of swelling and migration: A case study of plasticized polylactic acid food contact plastics tested with ethanolic food simulants. eXPRESS Polymer Letters, 18(4), 391–405. https://doi.org/10.3144/expresspolymlett.2024.29 (cited for SML exceedance in 50% ethanol and swelling from 20% ethanol)
- Massahi, T., Omer, A. K., Kiani, A., Mansouri, B., Soleimani, H., Fattahi, N., Moradi, M., & Sharafi, K. (2025). A simulation study on the temperature-dependent release of endocrine-disrupting chemicals from polypropylene and polystyrene containers. Scientific Reports, 15, Article 19318. https://doi.org/10.1038/s41598-025-05036-7 (cited for temperature-dependent EDC release from polypropylene vs polystyrene)
- Petrovics, N., Kirchkeszner, C., Tábi, T., Magyar, N., Kovácsné Székely, I., Szabó, B. S., Nyiri, Z., & Eke, Z. (2022). Effect of temperature and plasticizer content of polypropylene and polylactic acid on migration kinetics into isooctane and 95 v/v% ethanol as alternative fatty food simulants. Food Packaging and Shelf Life, 33, Article 100916. https://doi.org/10.1016/j.fpsl.2022.100916 (cited for temperature outweighing plasticiser content in migration kinetics)
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