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Food Packaging Brochure NW September 2016
Food Packaging Brochure NW September 2016
Manufacturers in the food packaging segment focus on the highest levels of manufacturing controls in line with
the imperative of protecting the consumer. Naturally, food packaging is also the subject of extensive legislation,
which applies to all the packaging components of a packaged food – including the label. It is the responsibility
of all suppliers in the food packaging value chain to ensure that proper materials are chosen for each package
they produce.
When considering the choice of inks to use on a package, a printer or brand owner should know if the ink will be
used for Direct or Indirect Food Contact.
- Direct food contact - is defined as when packages have printed areas that are intended to have direct contact
with the food stuff or whereby it can reasonably be expected the printed area will be brought into contact with
food or it can be expected the printed area will transfer their constituents to food under normal or foreseeable
conditions of use. In these cases, Direct Food Contact ink (known as DFC compliant) must be specified.
- Indirect food contact - If the foreseeable usage of the printed package does not result in direct contact between
the foodstuff and the print, then a food packaging compliant printing ink can be used. Depending on the industry,
these inks are also commonly known as ‘Low Migration’ products.
This guide focuses on definitions and best practices for use of food compliant inks in indirect food contact
applications.
Migration Examples
The transfer of a substance from the packaging to the food, or vice versa, is called migration and is a prime
concern for the food packaging supply chain. All materials in the package structure are evaluated for low
migration (inks, packaging substrates, lamination adhesives, adhesives for labels, etc.)
The diagram below shows the main types of migration for inks used in indirect food contact applications.
Ink design not only takes into consideration the possible migration due to penetration migration, but
also the unique circumstances that drive Set-Off Migration, Vapour Phase Migration and Condensation
Extraction.
Set-off Migration
Although it is invisible to the human eye, ink set-off can occur on the reverse side of printed labels, lids,
cups and packaging film, either in a stack, or in the reel after printing. This creates a potential that low-
molecular weight substances could be transferred to the unprinted surface of the packaging that makes
contact with the packed contents. To prevent Set-off Migration, the use of food compliant inks for indirect
food contact is recommended. Flint Group Narrow Web had designed these inks for low migration, and
their efficacy has been tested by certified testing laboratories.
Aluminium lid
Full barrier properties but potential
set-off to the reverse side, especially when
printed reel to reel or stacked and stored.
Container
Independent of barrier properties risk of
potential set-off to the reverse side when
stacked and thus bringing the printed outer
surface in contact with the unprinted inner
side of the container before filling.
Outside
Inside
The demonstrated and long history of safe food packaging indicates that the current regulations are effective
in guiding packaging material choices and designs that are fit for purpose. Although the compliance of food
packaging with regulations is ultimately the responsibility of the party placing the package on the market,
all participants in the supply chain play a role in achieving the final compliance. (for example; raw materials
providers, substrate and ink providers, printers, converters, package designers, and brand owners)
When it comes to inks, the same printing ink system can meet food packaging compliance or be unsuitable
depending on the substrate type or thickness it is printed on, the printing conditions, the food that is
packed within the printed packaging, the conditions during the packaging manufacturing and filling (for
example applied temperatures) and the way the food packaging is intended to be used (frozen, microwave
safe, etc.). For this reason the ink supplier alone can not take over responsibility for an ink being safe
for any specific application. This is also the reason regulations frequently define the migration limits of
compounds that may migrate from the packaging. And this is a reason why regulations also define the test
methods for measuring migration and migrants.
The Commission Regulation (EU) No.10/2011 and amendments, known as the Plastics Implementation
Measures (PIM), relates to plastic materials and articles intended to come into direct contact with foodstuffs.
The regulation lays down an overall migration limit (OML) of 60 mg/kg food or 10 mg/dm² of surface area.
In addition, specific migration limits (SML) or maximum contents in the material or article (QM) are set for
individual substances. It also contains a positive list of monomers and other starting substances used in the
manufacture of plastics intended for direct contact with food. Packaging inks that are not intended for direct
food contact are not therefore under the scope of this regulation. However, if there are components used in the
ink which are listed, the relevant restrictions in this regulation, such as specific migration limits or maximum
content, have to be met. The requirement to issue a declaration of compliance (DoC) also does not apply to
food packaging inks. In order to support packaging manufacturers to comply with this directive, Flint Group,
as a member of the European Printing Ink Association EuPIA, provides the information on the substances
appearing in the regulation and other potential migrants in an Enhanced Statement of Composition (e SoC).
Inks and coatings that do not have direct food contact are not regulated; as long as there is a “functional barrier” between
the food contact side and the ink or coating, and the inks and coatings do not migrate to the food contact side during
various steps in the process. It is the responsibility of the packaging manufacturer to determine if the construction meets
the definition of a functional barrier.
Printing Inks and Coatings for Indirect Food Contact – Barrier Function of the Packaging
Material
Where printing inks and coatings are separated from the packed food by one or several layers of packaging
material, the suitability of the ink or coating system is strongly depending on the barrier properties of the
packaging material and the extraction properties of the packed food.
Containers such as metal cans and glass bottles represent an absolute barrier, and therefore require no
special choice of printing ink, coating or printed label applied to the outside of the packaging.
However, there is lack of clarity in the packaging industry today on the ability of a plastic container and/
or filmic substrate to function as a barrier. This is due to the infinite number of combinations of food
type, packaging material and printing inks/coatings that are possible where the packaging layer might
show different barrier functionality. To ensure that the packaging material acts as a functional barrier,
preventing migration of components from the printed surface through the packaging material into the
packed food, migration tests on the complete packaging construction are recommended.
A printer can choose from multiple types of printing ink chemistry, when looking for a food packaging
compliant product. Traditionally, solvent based and water based packaging ink formulations have not
given any reason for concern, as they have been used historically without any documented issues. When
considering UV printing inks and conventional sheetfed inks, it is important to ensure that a compliant
product is selected. This often has been referred to as “low migration” products.
Food Packaging compliant inks are based on formulations that are optimised with respect to their migration
properties. They are tested under standardised migration test conditions to prove that under these
conditions they do not migrate above defined acceptable limits. However, due to the fact that these tests
can not simulate all possible food/ substrate combinations for which the printing inks finally might be used,
there can never be a 100% guarantee or warranty that the products will always work, but instead the whole
construction should be evaluated and a suitable risk assessment made.
The choice of simulant for any migration test is determined by the end use of the printed package. The
type of food to be packed combined with the shelf life of the product are the main determining aspects.
Simulants are described in the Commission Regulation (Eu) No. 10/2011 and its amendments:
Avoidance of Contamination
Special care should be taken to ensure that inadvertent use of materials unsuitable for food packaging
is prevented. For example when printing with food packaging compliant printing inks or varnishes, only
specially selected compliant ink additives (adhesion promoters, foam suppressors and others) should be
used. To avoid accidental use no other general ink additives should be in the press room close to the press.
Additionally, other graphic features that might be printed on top of the printed package, for example by
digital printing or thermal transfer ribbon printing, all have to be based on materials that have proven
migration compliance in order to ensure that migration from inks or coatings in the finished pack remains
within allowed limits.
It must be remembered that when setting up for a print job requiring a change from a conventional
printing ink to a food packaging compliant ink system, the press must be thoroughly cleaned to avoid any
contamination from materials that have a higher migration tendency. Generally speaking, it is appropriate
to have dedicated printing presses for printing food packaging to avoid this uncertainty.
The design of the packaging Other practical parameters for In the printroom
food packaging
amount of ink per surface unit print process and type of press
pack contents – food/liquid?
s ubstrate type and print speed
thickness t ime and pressure conditions
achieving a true barrier
in the stack or reel
functional barrier
c onventional drying or energy
performance of the substrate storage times and conditions
curing?
s ize of pack/container and length of time in contact with + choosing the right UV lamp
total print area food packaging
s urface print, reverse print,
expected maximum shelf life overlamination?
s pecial processing conditions likely level of residual solvents
for packs – e.g. sterilisation,
The use of additives
pasteurisation, heating, cooling
What is migration?
Migration is the transfer of substances from the packaging to the packed food products. The presence
of migrated substance traces can be measured by chemical analysis. Regulation is interested in the
migration of components that have a molecular weight of under 1000 Dalton, as any substance with a
higher molecular weight will not enter the biobarrier in the human body, and is therefore considered not
to be of concern.
FA
the proximity of the packaged goods, the greater the risk of migration. An ultimate equilibrium between the
migrant level in the food and its packaging will, however, be established. This is why the PIM regulation
takes storage time of the packed item into affect when determining testing conditions.
What migrates?
Potential migrants include any substance with a molecular weight below 1000 Dalton. This includes (but
is not limited to) plasticisers from plastics or inks; monomers from plastics or coatings; solvents, cleaning
chemicals, oils and greases; photo-initiators, hydrocarbon distillates or mineral oils from conventional inks.
Further information and technical support is available from Flint Group around the
world. Please contact:
[email protected]
[email protected]
The information contained herein is based upon data believed to be up-to-date and correct at the time of writing. It is provided
to our customers (and / or Analytical Contractors) in order that they are able to comply with all herein mentioned applicable
health and safety laws, regulations, and orders. In particular, customers in the EU are under an obligation to carry out a risk
assessment under relevant Good Manufacturing Practices (GMP) in-line with EU food contact legislation and as a result take
adequate risk management measures to protect food consumers. Where applicable legal obligations or provisions are not
mentioned within this document, this does by no means indicate that we deem such obligations or provisions irrelevant or
less relevant than those mentioned within the document. The statements in this document are not provided or deemed to be
provided as legal advice and you should seek the advice of a legal counsel to understand all of your obligations.