The updated guideline replaces September 2009 protocols issued by the trade body (which represents European printing ink makers) and applies to printing inks, coatings and varnishes (‘packaging inks’) applied to any material or article intended to come into contact with foodstuffs.
The framework EC regulation 1935/2004 requires that materials and articles in contact with food should be made according to good manufacturing practices, so that under “normal or foreseeable” conditions of use they do not transfer constituents to food in quantities that could, under Article 3:
(1) Endanger human health (2) bring about an unacceptable change in the composition of food, (3) bring about a deterioration of the organoleptic characteristics of food.
Once printed and dried/cured on the non-food-contact side of a packaging, inks become a food packaging component and must comply with the article’s requirements, EuPIA noted.
Plastic materials and articles
EUPIA said it recommended full traceability during ink production analogous to requirements under Article 17 of the same regulation, to ensure the straightforward recall of defective products, proper consumer information and the attribution of responsibility.
The “main specific measure” since the 2004 framework regulation was Regulation No 10/2011 (effective from May) EuPIA said, which governed plastic materials and articles intended to come into contact with food.
This lays down an overall migration – the transfer of printing ink components from packaging to food – limit (OML) of 60mg/kg of food or 10 mg per decimeter squared (dm2) of surface area, while specific migration limits (SMLs) or maximum contents in the material or article were also set for individual substances.
EuPIA noted that the regulation contained a positive list of substances authorised for use in the manufacture of plastics, with packaging inks in their supply form not within its scope, since they were subject to other EU or national rules.
But since printed plastic materials and articles were covered by the regulation, if ink components included on the positive list were used, SMLs or MCs must be met, the trade body warned.
Policing potential migration levels
EuPIA also revealed the terms of a “challenging continuous improvement programme” undertaken by the prinking ink industry to control potential migration levels of substances in packaging inks.
The body said that industry had agreed that substances without SMLs or tolerable daily intake (TDI) data should be subject to target migration limits – policed by the converter and printing ink producer – of 10 parts per billion (ppb) by December 2015.
An initial industry target of 50ppb (as per EFSA guidance for non-genotoxic substances) was set for last December.
Printing ink manufacturers had a responsibility to supply products fit for intended purpose, EuPIA said. “[But] they are not liable for any aspects of the production of food packaging once the packaging inks have left the manufacturing site.
“The manufacturer of the packaging and the filler are responsible for the properties of the food packaging and its compliance with legal requirement,” the trade body added.
The full EuPIA report is available to download here.