How to process the Italian DM21/03/73 report for aluminum foil composite packagi
Date：2026-08-14 09:52:29 Classification
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Guide to Aluminum Foil Composite Packaging Certification in Italy (DM21/03/73)
Aluminum foil composite packaging is a food contact material and must comply with the DM 21/03/73 sanitary regulation for export to Italy. The following is the complete application process and key points:
I. Regulatory Background
DM 21/03/73 is the Italian sanitary regulation for food contact materials, requiring that components migrating into food from the product must not exceed the specified limits. Because aluminum foil composite packaging involves multiple materials such as aluminum foil layers, plastic layers, adhesives, and inks, compliance must be assessed layer by layer.
II. Application Process (5 Steps)
1. Step 1: Material Review
Provide complete structural information of the aluminum foil composite packaging: material of each layer (PET/PA/AL/PE/CPP, etc.), adhesive type, and printing ink composition.
Clarify the intended food contact type of the product: contact with dry food, oily food, acidic food, or microwaveable food.
2. Step 2: Laboratory Selection
A third-party laboratory officially accredited by the Italian Ministry of Health must be selected.
Prioritize institutions with ISO 17025 accreditation and experience cooperating with Italian certification bodies (DEZEW Testing CNAS Registration No.: L8083).
3. Step 3: Sample Submission and Testing
Routine testing cycle: 5-15 working days (due to the involvement of multiple materials in joint testing)
Key test items:
Total migration test: Total amount of non-volatile substances released under simulated food contact conditions.
Specific migration test: Heavy metals (lead, cadmium, chromium, nickel, etc.), aromatic amines, phthalates, primary aromatic amines (PAA).
Special attention: Aluminum layer migration, printing ink migration, adhesive migration.
4. Step 4: Report Issuance
The laboratory will issue a bilingual test report in Italian and English.
The report must include: sample description, migration conditions (simulated food, temperature, time), limit requirements, and result interpretation.
5. Step 5: Compliance Application
After passing the test, the report serves as a compliance certificate for customs clearance and sales in the Italian market.
It is recommended to simultaneously retain technical documents (including formula, test report, and production process) for at least 5 years.
III. Fees and Timeframe
| Item | Standard Range
| Basic Testing Fee | 800-2000
| Testing Timeframe | 5-7 working days
| Report Validity | Typically 3 years (some laboratories may extend to 5 years)
IV. Key Considerations
Migration Testing Conditions: Select the appropriate simulation solution (e.g., water, 3% acetic acid, 10% ethanol, olive oil, etc.) and temperature (room temperature, 70℃, 100℃, etc.) based on the actual application. Different applications require separate evaluation.
Ink Layer Focus: The outer printing ink of aluminum foil composite packaging is a key risk point. Ensure the ink composition complies with Italian regulations, especially regarding aromatic amines and heavy metal migration.
Simultaneous Evaluation Recommendation: To improve overall EU customs clearance efficiency, it is recommended to simultaneously test against EU general regulations such as EU 1935/2004 and EU 10/2011 to avoid duplicate sampling.
Aluminum Layer Compliance: For pure aluminum layers, focus on aluminum ion migration, especially when in contact with acidic foods.
Manufacturer's Declaration: It is recommended to prepare an additional Declaration of Conformity (DOC) clearly stating that the product complies with DM 21/03/73 requirements.
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