The new frontier of MOCA analysis

In recent years, those working in the world of food contact materials and articles have perceived a decisive shift. A silent yet profound transition, which is changing the very way material safety is assessed. This shift is not driven solely by technological innovation in polymers, metallic materials, multimaterials, or recycled paper, nor by the push towards sustainability. The main driver of this change is the evolution of the regulatory approach and analytical chemistry: we have entered an era in which non targeted screening analyses are becoming more important than traditional targeted tests.

The new European regulatory framework clearly explains why this is happening. With Regulation (EU) 2025/351, which introduces stricter requirements on the quality and purity of substances used in MOCA, it is no longer sufficient to verify compliance only for known, authorised substances already included in the positive lists. Furthermore, with the European Commission’s One Substance One Assessment approach, the formal distinction between IAS and NIAS loses relevance: substances are assessed in an integrated and qualitative manner based on their intrinsic properties and risk profile, regardless of whether they are intentionally used or generated incidentally.

Legislators are now calling for a further step: identifying all substances already present in the raw material and throughout the entire production cycle. Only in this way is it possible to determine their true toxicological profile and demonstrate that the material is safe for consumers.

This is where the need – and the urgency – for broader, more sensitive analytical tools arises, capable of detecting what we do not yet know we should be looking for. Targeted analyses, based on the identification of specific molecules, remain essential but are no longer sufficient. The complexity of modern materials, especially recycled ones, introduces degradation compounds, impurities, oligomers, and newly formed products that escape traditional approaches. It is precisely in this context that screening techniques emerge as the structural response of the sector.

Their strength lies in the breadth of the investigative field: chromatographic methods are applied, separating and identifying contaminants through coupling with mass spectrometry, such as HS GC MS for volatile compounds, GC MS for semi volatile compounds, LC QTOF for non volatile substances and emerging contaminants; when these techniques are integrated with spectroscopic and thermal techniques such as FT IR, DSC, and TGA, they form an observation network capable of providing a complete material profile.
It is no longer just about detecting a chromatographic peak: today, an advanced laboratory reconstructs the molecular formula, evaluates isotopic distribution, compares spectra with scientific and proprietary libraries, and finally confirms compound identity through dedicated MS/MS analyses. This process requires high level expertise and robust technological infrastructure, but it allows laboratories to intercept, identify, and assess substances that would previously have gone unnoticed. To understand the real impact of this approach, it is enough to observe what happens daily in laboratories.

Screening based on thermal and infrared investigations makes it possible to identify the main components, while impurities that are hazardous for consumers are detected using chromatographic techniques.
Likewise, combining screening with risk assessment that includes toxicological impact makes it possible to address conclusions in a harmonised manner when assessing material safety. A key role in this process is played by instrumental libraries as well as NIAS databases, which are true repositories of chemical knowledge accumulated in the field. These databases, built on thousands of analysed samples —plastic, paper, and multimaterials— now contain thousands of unique compounds, each accompanied by a risk assessment. Thanks to these libraries, laboratories can recognise recurring patterns, identify substances in a matter of minutes that once required weeks, and provide manufacturers with concrete guidance to improve processes and formulations.

The shift towards screening is not only a regulatory issue, nor merely a technical one. It also has a cultural impact: it pushes the entire supply chain to abandon the idea of a standard control valid for all situations and to move towards a risk based analysis model, tailored to the specific combination of material, process, and application. This means that analytical chemistry is no longer just a final control, but becomes an integral part of packaging design, especially as the sector increasingly moves towards sustainable packaging.

The recycling of plastics, paper, and other materials, as well as the use of innovative materials, inevitably introduces a higher degree of variability compared to virgin materials. Without screening investigations, it would not be possible to guarantee safety and performance at an industrial level, nor to accurately assess complex phenomena such as substance release or microplastics, or interactions between layers in multilayer structures. To assess the real impact on consumers, evaluation is increasingly extended to the real food itself when simulants do not provide reliable answers. Heavy metals, organic compounds in contact with complex matrices: these are all areas in which direct food analysis, when carried out using validated and, where possible, accredited protocols, adds a crucial element to risk assessment.

The direction is clear: in the MOCA world, screening is no longer an optional extra, but a cornerstone, and it must be carried out using multiple techniques, among which liquid chromatography coupled with high resolution mass spectrometry (LC HRMS, or LC HR MS) can no longer be overlooked, to ensure control of medium heavy or polar contaminants. Laboratories are called upon to integrate techniques, share methods, build databases, collaborate in working groups, and continuously update their knowledge. Consumer safety and material innovation cannot be guaranteed with yesterday’s tools and approaches. And today more than ever, knowing what you are looking for is less important than knowing what is actually present in a material.