Terry Knowles, European Editor12.21.22
The European Commission has announced that its ongoing review and revision of European Union food-contact material (FCM) legislation is likely to be delayed until early 2023, citing the importance of linking the FCM rules with the EU's newer chemicals strategy.
The European Printing Ink Association (EuPIA) and the Packaging Ink Joint Industry Task Force (PIJITF) have provided feedback as part of this industry consultation and have asked that prioritization should be given to the timely development of further measures for non-harmonized materials, especially printed FCMs, and such specific measures should incorporate industry risk assessment for non-listed substances.
Detailed rules on good manufacturing practice (GMP) for processes involving the application of printing inks on the non-food contact side of a material or article are set out in the Annex of the
the GMP Regulation (EC) No 2023/2006.
These rules state that the substances should not be transferred to the food contact side during processing or storage at levels which would not comply with the Food Contact Framework Regulation (FCFR) (EC) No 1935/2004. It also states that the printed surfaces from such printing processes shall not come into direct contact with food.
This does not mean direct contact between ink layers and food is not allowed. Specially designed inks that fulfil very strict composition requirements that comply with Article 3 of the FCFR, are allowed on surfaces in direct contact with foodstuffs.
The following points are also clarified by the ECMA's guidance:
• The new German Ink Ordinance covers both direct and indirect contact printing. For the Direct Food Contact (DFC) inks only the listed substances can be used, self-evaluated
substances are not allowed.
Different documents available from EuPIA (www.eupia.org) cover the specific guidance in relation to DFC applications. (EuPIA Guideline on printing inks applied to Food Contact Materials, EuPIA GMP, EuPIA Guidance on migration test methods for the evaluation of substances in printing inks and varnishes for food contact materials).
• Secondly, the ECMA highlighted a second source of confusion is due to the naming of certain ink series. So-called "FCM (Food Contact Material) inks" are actually not suitable for direct contact printing. DFC inks are required for such applications. FCM inks themselves have been designed for use on food contact materials in cases where no functional barrier is present and on the surface that is not in physical contact with the food.
The EuPIA GMP further specifies that the presence of an overprint varnish does not change the contact character of the ink. With the presence of a DFC overprint varnish, it is still necessary to use a DFC ink on the direct contact side.
This guide includes the resolution and its guiding principles and offers technical guidance relating to the requirements, compliance testing and supporting documentation for paper and board materials. It was drafted by the European Committee for Food Contact Materials and Articles (CD-P-MCA) and was subject to a public stakeholder consultation in 2020.
The document has been developed with the aim of improving the protection of consumers against contaminants (metals, antioxidants, stabilizers, colorants, plasticisers, etc.) potentially released by materials in contact with food (packaging, containers, plates, cups, straws, baking and filter papers, napkins, etc.).
It also seeks to support the harmonisation of regulatory approaches to consumer health protection across Europe. The document, which has been published in English and French, can be downloaded free of charge at https://freepub.edqm.eu/publications/PUBSD-115/detail
The collective picture for the next five years until 2027 is not exactly positive. Overall print volumes have already fallen by 21% between 2017 and 2022 to 10.1 trillion A4 prints and look set to fall by another 6% to about 9.5 trillion by 2027.
Value-wise, things are little better; the value of print and printed packaging has fallen by nearly 8% in the last six years (inclusive) from €173 billion in 2017 to €159.2 billion in 2022. What recovery there is from this decline is measured in constant currency terms and amounts to a valuation of €165.3 billion by 2027; this is equivalent to overall growth of 3.8% in the next five years.
To its credit, Europe has a lot of advanced print technology that it can harness in the future. Although it is apparent that there is some long-term decline in the digital age, the report highlights where there are growth opportunities for industry and some of the more positive influences for the sector across 27 European countries.
Currently and in common with other prevailing European trends, print providers and their suppliers are grappling with the impact of a so-called 'printflation' as far as inks, papers, plates, energy and transportation costs are concerned.
This multi-term equation is expected to depress demand for published materials and graphic printing just as consumers struggle with print budgets and a much wider economic uncertainty, which is never good for business.
Europe-wide uncertainty over energy availability as well as energy price is currently affecting print supplies across the continent, and in the east of the continent the Ukraine-Russia conflict has impacted both of the national industries and this also has a domino effect on that of other economies in Eastern Europe too.
The European Printing Ink Association (EuPIA) and the Packaging Ink Joint Industry Task Force (PIJITF) have provided feedback as part of this industry consultation and have asked that prioritization should be given to the timely development of further measures for non-harmonized materials, especially printed FCMs, and such specific measures should incorporate industry risk assessment for non-listed substances.
ECMA Clears Up Confusion on Food Contact Inks
In light of some of the recent developments in food contact inks in Europe, which I touched upon in my last column, The European Carton Makers' Association has recently issued some guidance that aims to clarify which types of inks are suitable for direct food contact. The statement has been prompted by the association regularly fielding questions about which inks offer regulatory compliance.Detailed rules on good manufacturing practice (GMP) for processes involving the application of printing inks on the non-food contact side of a material or article are set out in the Annex of the
the GMP Regulation (EC) No 2023/2006.
These rules state that the substances should not be transferred to the food contact side during processing or storage at levels which would not comply with the Food Contact Framework Regulation (FCFR) (EC) No 1935/2004. It also states that the printed surfaces from such printing processes shall not come into direct contact with food.
This does not mean direct contact between ink layers and food is not allowed. Specially designed inks that fulfil very strict composition requirements that comply with Article 3 of the FCFR, are allowed on surfaces in direct contact with foodstuffs.
The following points are also clarified by the ECMA's guidance:
• The new German Ink Ordinance covers both direct and indirect contact printing. For the Direct Food Contact (DFC) inks only the listed substances can be used, self-evaluated
substances are not allowed.
Different documents available from EuPIA (www.eupia.org) cover the specific guidance in relation to DFC applications. (EuPIA Guideline on printing inks applied to Food Contact Materials, EuPIA GMP, EuPIA Guidance on migration test methods for the evaluation of substances in printing inks and varnishes for food contact materials).
• Secondly, the ECMA highlighted a second source of confusion is due to the naming of certain ink series. So-called "FCM (Food Contact Material) inks" are actually not suitable for direct contact printing. DFC inks are required for such applications. FCM inks themselves have been designed for use on food contact materials in cases where no functional barrier is present and on the surface that is not in physical contact with the food.
The EuPIA GMP further specifies that the presence of an overprint varnish does not change the contact character of the ink. With the presence of a DFC overprint varnish, it is still necessary to use a DFC ink on the direct contact side.
EDQM Publishes Guidance Paper for FCM Sector
Recently, the European Directorate for the Quality of Medicines & Healthcare (EDQM) published the first edition of its technical guide “Paper and board used in food contact materials and articles”, following the October 2020 adoption of the resolution on the safety and quality of materials and articles for contact with food by the Committee of Ministers of the Council of Europe.This guide includes the resolution and its guiding principles and offers technical guidance relating to the requirements, compliance testing and supporting documentation for paper and board materials. It was drafted by the European Committee for Food Contact Materials and Articles (CD-P-MCA) and was subject to a public stakeholder consultation in 2020.
The document has been developed with the aim of improving the protection of consumers against contaminants (metals, antioxidants, stabilizers, colorants, plasticisers, etc.) potentially released by materials in contact with food (packaging, containers, plates, cups, straws, baking and filter papers, napkins, etc.).
It also seeks to support the harmonisation of regulatory approaches to consumer health protection across Europe. The document, which has been published in English and French, can be downloaded free of charge at https://freepub.edqm.eu/publications/PUBSD-115/detail
An Outlook for the European Print Sector
It's not often that reports are dedicated solely to Europe these days, so I wanted to tuck in here a mention of the recent Smithers report “The Future of European Print to 2027,” which is dedicated to the continent's print and printed packaging market.The collective picture for the next five years until 2027 is not exactly positive. Overall print volumes have already fallen by 21% between 2017 and 2022 to 10.1 trillion A4 prints and look set to fall by another 6% to about 9.5 trillion by 2027.
Value-wise, things are little better; the value of print and printed packaging has fallen by nearly 8% in the last six years (inclusive) from €173 billion in 2017 to €159.2 billion in 2022. What recovery there is from this decline is measured in constant currency terms and amounts to a valuation of €165.3 billion by 2027; this is equivalent to overall growth of 3.8% in the next five years.
To its credit, Europe has a lot of advanced print technology that it can harness in the future. Although it is apparent that there is some long-term decline in the digital age, the report highlights where there are growth opportunities for industry and some of the more positive influences for the sector across 27 European countries.
Currently and in common with other prevailing European trends, print providers and their suppliers are grappling with the impact of a so-called 'printflation' as far as inks, papers, plates, energy and transportation costs are concerned.
This multi-term equation is expected to depress demand for published materials and graphic printing just as consumers struggle with print budgets and a much wider economic uncertainty, which is never good for business.
Europe-wide uncertainty over energy availability as well as energy price is currently affecting print supplies across the continent, and in the east of the continent the Ukraine-Russia conflict has impacted both of the national industries and this also has a domino effect on that of other economies in Eastern Europe too.