Food contact materials (FCMs) i.e. materials that food is packaged or handled in, must be safe for their intended use. European FCM legislation uses a risk-based approach, with a cornerstone of FCM’s safety evaluation being measurement of migration of substances from FCMs to food simulants. The standard methods mainly developed for plastic FCMs are not always suitable for less inert and moisture sensitive materials such as paper and board. However, these are becoming increasingly common as FCMs e.g. to replace single-use plastics. In addition, there is a drive to further use recycled materials. To support this development, new methods for assessing the safety of these materials are needed. In the present feasibility study, a hydrogel crosslinked through freeze-thawing of poly(vinyl alcohol) was evaluated as a food simulant for moist foods. The migration of surrogate compounds from a spiked paperboard to the hydrogel was determined and compared to the migration to a real moist food (a slice of apple), the commonly used modified polyphenylene oxide (MPPO) and a water extract. Migration of polar surrogates to the hydrogel correlated well with the migration to the apple slice. However, our results indicate that the hydrogel is less suitable as simulant for non-polar surrogates. Overall, the study demonstrates the potential of this hydrogel-based simulant for improving risk assessment of less inert FCMs.