Cling Film Plasticizers: DEHA vs ATBC Limits 2026

Quick answer: Food-grade PVC cling film is 25-35% plasticizer by weight, and the plasticizer is the part regulators actually control. In the EU, DEHA has a specific migration limit of 18 mg/kg (equivalent to 3 mg/dm² for a roll of film), while ATBC has no individual limit at all — both are caught by a 60 mg/kg cap on the sum of all plasticizers. In the US there is no migration limit; FDA instead caps how much plasticizer you may load, by film thickness and by the fat content of the food, and clears DEHA on fatty food only for refrigerated and frozen contact. Those are two completely different compliance logics applied to the same roll, and a film can satisfy one while failing the other.

We extrude PVC and PE food film at Ningbo Sanrong New Materials and ship to more than 50 countries, which means writing declarations of conformity for both systems every week. This guide is the version we wish buyers had before they send us a spec: what each plasticizer actually does on the line, which numbers bind in which market, and the five checks that tell you whether a migration report is worth anything.

Why Cling Film Is Mostly Plasticizer, and PE Film Has None

Unplasticized PVC is a rigid material — it is what window profiles and drainpipes are made from. Everything that makes cling film film comes from the plasticizer: the plasticizer molecules sit between the polymer chains, lower the glass transition temperature below room temperature, and leave a soft, tacky surface that wets a plate and stays there.

That means two things a buyer should internalise:

1. Plasticizer content is not a trace additive, it is a quarter to a third of the product. A 30 cm × 300 m roll of 9 µm PVC film holds about 1.0 kg of film (90 m² × 9 µm × 1.25 g/cm³), of which roughly 250-350 g is plasticizer. Nothing else in the formulation is close.
2. Cling and migration are the same physical property viewed from two sides. A plasticizer mobile enough to give a soft, high-tack surface is mobile enough to move into fat. There is no formulation that is simultaneously the clingiest and the lowest-migration option; every specification is a position on that trade-off.

PE cling film works completely differently. It has no plasticizer at all — the cling comes from a tackifier, usually polyisobutylene (PIB), blended into a low-density polyethylene base. That is why PE film is the default answer whenever a buyer’s real requirement is “no plasticizer migration”, and why PE film also clings noticeably less well to glass and ceramic. We compare the two materials in detail in our PVC vs PE cling film guide.

The Four Chemistries You Will Actually Be Offered

Ignore the long lists in chemistry references. In food cling film in 2026, a Chinese, Indian or Turkish factory will quote you one of these:

Plasticizer	CAS	Typical loading	Cling	Cold flexibility	Migration into fat	Relative cost
DEHA (di(2-ethylhexyl) adipate)	103-23-1	25-35%	Highest	Very good to −20 °C	Highest of the food-grade group	Baseline (1.0)
ATBC (acetyl tributyl citrate)	77-90-7	25-35%	Good, slightly lower tack	Good	Substantially lower than DEHA	~1.4-1.8×
ESBO (epoxidised soybean oil)	8013-07-8	2-5%	Minor contribution	Neutral	Low but counts to the total	~1.2×
Polymeric adipate (polyester)	varies	5-15% as part blend	Reduces tack	Poorer at low temperature	Lowest (high molecular weight)	~2-3×

Three notes from the extrusion floor that do not appear in supplier brochures:

• ESBO is not optional the way buyers assume. It works as an acid scavenger for the HCl that PVC liberates under heat, protecting the film from yellowing. Removing it to reduce the total plasticizer count usually costs you colour stability instead. It also carries its own EU limit of 60 mg/kg, dropping to 30 mg/kg for PVC gaskets on glass jars of infant formula, with a specification of oxirane content below 8% and iodine number below 6.
• Polymeric adipates are the migration answer nobody wants to pay for. Because the molecule is large it barely migrates, but it costs two to three times DEHA, raises melt viscosity, and drops cling. We use it as a partial replacement in machine-grade film where cling is delivered by the tray overwrapper rather than by the film itself.
• “Non-phthalate” is not a specification. DEHA, ATBC and ESBO are all non-phthalate. If a supplier’s headline claim is “phthalate-free”, they have told you nothing that has not been true of every compliant food film for a decade. Ask which plasticizer, at what loading, with what migration result.

The EU: Three Numbers Bind, Not One

Almost every buyer knows the 18 mg/kg figure. Most compliance failures we see involve the other two.

Under Commission Regulation (EU) No 10/2011 (consolidated text as at 31 August 2023, which incorporates Regulation (EU) 2023/1442):

What it controls	Limit	Where it comes from
DEHA alone	SML 18 mg/kg food	Annex I, Table 1, FCM No 207 (Ref. 31920)
ATBC alone	no individual SML	Annex I, Table 1, FCM No 138 (Ref. 93760)
ESBO alone	60 mg/kg, or 30 mg/kg for infant-food jar gaskets	Annex I, Table 1, FCM No 532
Sum of all plasticizers	SML(T) 60 mg/kg	Annex I, Table 2, group restriction 32
Sum of DBP + DIBP + BBP + DEHP	0.6 mg/kg as DEHP equivalents	Annex I, Table 2, group restriction 36
Sum of DINP + DIDP	1.8 mg/kg	Annex I, Table 2, group restriction 26

Group restriction 32 is the one that catches people. It lists roughly twenty FCM substances — including ATBC (138), triethyl citrate (140), DEHA (207), ESBO (532) and the phthalates — and sets a single SML(T) of 60 mg/kg expressed as the sum of the substances (plasticizers). So:

• An ATBC film is not exempt just because ATBC has no individual number. It is governed by the 60 mg/kg total.
• A DEHA film that comes back at 15 mg/kg looks compliant against the 18 mg/kg SML, but if ESBO and a secondary plasticizer add another 50 mg/kg, the film fails group 32.
• If your supplier’s report shows only a DEHA figure, it does not demonstrate compliance. It demonstrates one line of a two-line test.

The 6 dm²/kg rule turns mg/kg into mg/dm²

Article 17(1) of 10/2011 says migration is expressed in mg/kg using the real surface-to-volume ratio in actual use. But Article 17(2)(c) carves out “sheets and films that are not yet in contact with food” and applies a conventional ratio of 6 dm² per kg of food. A roll in a warehouse is exactly that case. So:

18 mg/kg ÷ 6 dm²/kg = 3 mg/dm²

That is the number a laboratory will print for film tested off the roll, and it is why enforcement reports on cling film are usually quoted in mg/dm². Note the exception written into the same paragraph: the conventional ratio does not apply to material intended for contact with food for infants and young children.

The fat reduction factor trap

Annex V, point 4.1 allows a fat reduction factor (FRF) for lipophilic substances in food containing more than 20% fat:

FRF = (g fat per kg of food) / 200 = (% fat × 5) / 100

Test results are divided by the FRF before comparison with the limit. Column 7 of Annex I says whether it is applicable per substance — and here DEHA and ATBC differ. DEHA is marked FRF-applicable; ATBC is not. But three restrictions blunt this in cling film specifically:

1. The FRF may not be used when migration was calculated using the conventional 6 dm²/kg ratio — which is exactly how film off the roll is assessed.
2. It may not be used for material intended for food for infants and young children.
3. Migration must not exceed 60 mg/kg before the FRF is applied, in any case.

The practical effect: a fatty-food FRF that helps a rigid container often cannot be claimed for a roll of cling film. If a supplier’s report clears an otherwise failing result “after FRF”, ask on what surface-to-volume basis the result was calculated.

The US: FDA Regulates the Recipe, Not the Result

Buyers who work both markets often assume FDA has an American version of the SML. It does not. There is no migration number for DEHA in US regulation. Instead, 21 CFR 178.3740 (Plasticizers in polymeric substances) clears DEHA for PVC food-contact use with limits on loading, thickness, food type and storage temperature:

Tier	Max DEHA loading	Max film thickness	Food type	Conditions of use
1	24% by weight	0.005 in (127 µm)	Non-fatty, non-alcoholic	Any
2	24% by weight	0.005 in (127 µm)	Fatty, non-alcoholic, fat + oil ≤ 30%	F and G only
3	35% by weight	0.002 in (50.8 µm)	Non-fatty, non-alcoholic	Any
4	35% by weight	0.002 in (50.8 µm)	Fatty, non-alcoholic, fat + oil ≤ 40%	F and G only

Conditions of use F and G are defined in table 2 of 21 CFR 176.170(c): F = refrigerated storage and G = frozen storage, both with no thermal treatment in the container.

Read the table again with a cling film in mind. Household and foodservice film is 8-14 µm, far below the 0.002 in ceiling, so tier 3 and tier 4 apply and a loading up to 35% is available. But tier 4 is the only route for fatty food, and it says refrigerated or frozen, fat content no more than 40%. That excludes:

• a warm buffet tray of fatty food filmed over at room temperature;
• microwave reheating with the film touching food;
• anything above roughly 40% fat, which includes most hard cheeses, butter and many cured meats.

This is why our answer to “can we use your PVC film in a hot-hold cabinet?” is always no, and why the honest meat and seafood specification is refrigerated-case film.

ATBC and epoxidized soybean oil take a different US route: both appear in 21 CFR 181.27 (Plasticizers) as prior-sanctioned substances for food packaging, with the ESBO entry specifying an iodine number of maximum 6 and oxirane oxygen of minimum 6.0%. Notice the mirror image with the EU, which caps oxirane below 8% with iodine number below 6. A single ESBO grade can satisfy both, but only if someone checks — the two rules constrain the same parameter from opposite directions.

The citation to stop using

Compliance statements circulating in this industry routinely claim “PVC cling film complies with FDA 21 CFR 177.1580.” 21 CFR 177.1580 is the regulation for polycarbonate resins. It has nothing to do with vinyl film. There is no single FDA section that covers a PVC cling film, because the film is cleared component by component. A serious US statement of compliance cites 178.3740 for the plasticizer, 181.27 for prior-sanctioned components, and the applicable clearances for the resin and the Ca-Zn stabiliser system. If you see 177.1580 on a document, treat it as a signal that the document was copied rather than prepared.

EU vs US on the Same Roll of Film

Question	EU (Reg. 10/2011)	US (21 CFR)
Regulatory logic	Limit what migrates	Limit what you put in
DEHA control	SML 18 mg/kg (= 3 mg/dm²)	≤ 24% or 35% by weight, by thickness
Total plasticizer control	SML(T) 60 mg/kg (group 32)	None as a sum
Fatty-food control	Simulant D2 testing, FRF rules	Fat ≤ 30% or ≤ 40%, conditions F/G
Temperature control	Test condition (OM1, OM2 …)	Conditions of use letter
Phthalates in single-use food film	Effectively closed (groups 32, 36, 26)	Authorizations for 23 phthalates revoked in 2022 as abandoned uses
Document you must hold	Declaration of Conformity + supporting migration data	Statement of compliance citing each clearance

The column that surprises importers is total plasticizer. A formulation optimised for the US — maximum loading for maximum cling, all legal — can be compliant in the US and fail group 32 in the EU. If you ship the same SKU to both, specify to the stricter of the two and state it once.

Where Films Actually Fail: Four Patterns from the Factory Side

European enforcement campaigns in the 1990s found large shares of PVC cling films over the 3 mg/dm² DEHA limit when used on fatty food, and although formulations have improved enormously since, the failure modes have not changed. Having reformulated film after a few of those results, here is where they come from.

1. The film was fine; the application was not. A film specified and tested for refrigerated produce is put on a cheese counter. Migration scales with fat contact and time, so the same roll passes one use and fails another. The specification must name the food, not just the film.

2. Nobody summed the plasticizers. The single most common documentary gap. The DEHA result is reported, ESBO and secondary plasticizers are not, and group 32 was never evaluated.

3. Loading drifted upward for cling. When a customer complains that film is “not sticky enough”, the cheapest fix on a compound line is more plasticizer. Two or three of those adjustments and a film that was tested at 28% is running at 34%. Ask for the compound recipe to be locked to the tested formulation in the PO, and for a retained sample per lot.

4. Container heat did the rest. A 40 ft container crossing the equator reaches 55-60 °C inside. Plasticizer mobility rises sharply, which shows up as blocked rolls and edge bleed. It does not change the certificate, but it changes the film that arrives. This is one reason we discuss stuffing and ventilation in the container loading guide.

What to Put in Your Purchase Order

Copy this block, delete what does not apply, and send it with your enquiry. A supplier who can answer all eight lines without hedging is running a real compliance system.

1. Plasticizer identity and CAS number (e.g. DEHA, 103-23-1 — not “food-grade plasticizer”).
2. Loading, % w/w, with a tolerance (e.g. 30% ± 2%), locked to the tested formulation for the life of the PO.
3. Co-stabiliser / ESBO content, % w/w, with the oxirane and iodine values.
4. Target market(s), so the supplier tests against the right rule set.
5. Named food contact: food type, fat content, contact temperature, contact duration.
6. Required test: EU 10/2011 simulant D2 under the matching OM condition, results expressed on a 6 dm²/kg basis, reporting both the individual substance and the sum against group restriction 32.
7. US statement of compliance citing 21 CFR 178.3740 (with the tier) and 21 CFR 181.27 where applicable.
8. Declaration of Conformity per Article 15 of Regulation (EU) No 10/2011, re-issued on any formulation change.

Our own compliance pack and what it contains is described in the food safety compliance guide, and the broader certificate landscape (FDA, EU, halal, SGS) is in the certification guide.

Where This Guidance Runs Out

Four honest boundaries, because a specification written on false confidence is worse than no specification.

• Consolidated legal texts lag. The EU figures above are taken from the consolidated text of Regulation (EU) No 10/2011 as at 31 August 2023. Annex I is amended regularly; before you write a limit into a contract, check the current consolidated version on EUR-Lex for the specific FCM number.
• Migration is not linear with time or temperature. The models used to extrapolate a 10-day test to a six-month shelf life assume Fickian diffusion in a rubbery polymer. Near the glass transition, and with the fat phase swelling the film, real migration can exceed the extrapolation. Test at the condition you actually use.
• “Fat content of the food” is not the same as “fat at the interface”. A 20% fat product with free surface oil behaves like a much fattier food against the film. Marbled meat and oily fish are the classic cases.
• National rules sit on top of both systems. China’s GB 4806 series and the GB 9685-2016 additive standard, Japan’s Positive List under the amended Food Sanitation Act, and Gulf and Mercosur requirements all impose their own documentation. We can supply against them, but nothing in this article should be read as their numerical limits.

Related Guides

• PVC Cling Film Food Safety Compliance: FDA, EU 10/2011, Halal & SGS
• Cling Film & Saran Wrap Thickness Chart: Micron, Mil & Gauge
• PVC Cling Film for Meat & Seafood: Safety, Shelf Life and Best Practices
• What Is PVC Cling Film? How It’s Made and Why It Dominates Food Wrapping
• PVC Cling Film vs PE Cling Wrap: Complete Comparison for B2B Buyers
• PVC Cling Film Product Page — Specifications and Formats

Get a Formulation That Matches Your Market

Tell us the destination market, the food your film will touch, its fat content and the storage temperature, and we will come back with the plasticizer system we recommend, the loading, an FOB Ningbo price at your roll size, and the test plan that will support your Declaration of Conformity. If you already import film, send us the current spec sheet and migration report — we will read it against the rules above and tell you what is missing, at no charge and with no obligation to order.

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