In its most current document (“1_ECMA Position UV inks 07 04 2009 FV”), our European umbrella association ECMA reiterates its recommendations of foregoing use of UV inks and varnishes for primary food packaging (made from cardboard), or switching to the use of alternative materials – even when these are more cost-intensive – which have been evaluated by an independent third party. In addition, the ECMA recommends working towards carrying out a common risk assessment for every foodstuff commodity alongside branded companies/bottlers, in order to judge the potential interactions between the packaging and the packaged goods. The position of the ECMA in this matter is advocated by the European Commission (DG Sanco), the Confederation of Food and Drink Industries of the EEC (CIAA), the European Printing Ink Association (EuPIA), and by the Packaging Ink Joint Industry Task Force. From the beginning of the 4MBP case, the ECMA pointed out the responsibility of the raw material manufacturers as partners in the supply chain “Lebensmittelbedarfsgegenstand” and ,correspondingly, addressed letters to the EuPIA (“2_Letter EuPIA 4MBP”) and the Confederation of European Paper Industries (CEPI Cartonboard) (“3_Letter CEPI CB 4MBP “).The EuPIA have since written a letter of response (“4_090312 EuPIA reply to ECMA”), although, in this regard, they emphasise that they do not share the position expressed by the EMCA.
There is currently a declaration from Mayr-Melnhof Karton on the part of the board industry (“5_MMK BenzophE”). We are still awaiting an answer from CEPI Cartonboard.