Regulation (EG) No. 1935/20041 dictates that consumer goods which are designated finished goods and which come into contact with foodstuffs or which come into use with foodstuffs as part of their intended use may not form any part of the pre-packaged foodstuffs in amounts that would endanger human health or cause an irreversible change in the composition or an impairment of the organoleptic characteristics of the foodstuffs.
This means that the manufacturer of the finished end product and the packer both carry the legal responsibility of ensuring that the food packaging is suitable for its intended use .
1. EuPIA member companies offer tailor-made odourless sheet-fed offset inks with low migration and dispersion coatings in the manufacture of their primary paper and cardboard food packaging, and recommend these for this purpose. These are formulated and manufactured in accordance with the “EuPIA Guideline for printing inks to be used on food packaging surfaces facing away from the food and on objects “ and the “Good Manufacturing Practice for the production of packaging inks to be used on food packaging surfaces facing away from the food and objects (GMP)“.
Under the condition that these colours and coatings are implemented on suitable printing substrates, it is possible to manufacture primary food packaging with a lower rate of migration, which fulfil the specifications in Regulation (EG) 1935/2004.
2. This is in contrast to UV-hardening Standard2 sheet-fed offset inks and coatings, which are not designed for the production of primary food packaging. In addition, standard printing inks are not formulated and produced in compliance with the EuPIA Guideline or the EuPIAGMP.
The majority of these products contain substances (e.g. mineral oil or photoinitiators), which have not been assessed for contact with foodstuffs and which could transfer onto the food from the colour or coating, whether through migration via the substrate or via the vapour space, or via invisible set-off from the printed outer side onto the side facing the foodstuff while in the pile or roll.
3. EuPIA would like to make expressly clear that, within the framework of a risk disclosure, there are no completely effective barriers against the migration of substances from printing inks and dispersion coatings with regards to packaging made from paper, cardboard, as well as plastics such as PE or PP. Further information can be found on the EuPIA Info Sheet “Printer Inks for Food Packaging”.