David Savastano, Editor01.16.20
Meeting regulatory mandates is a major issue for the ink industry. Brand owners and converters want to know what is on the inks they are using, and ink manufacturers note that customers and CPG companies are asking for disclosure of proprietary information on ink formulations. These requests have to be handled judiciously.
George Fuchs, NAPIM’s director of regulatory affairs and technology, said that requests for detailed compositional data are becoming an increasingly common issue in the US.
“In other geographic regions outside the US, it is either a requirement or a common industry practice,” Fuchs added. “Within the US, this type of disclosure of compositional information generally occurs only under a legally binding, non-disclosure agreement between supplier and customer.”
Deanna Klemesrud, global marketing director-brand & promo, packaging inks and resins for Flint Group, said that there does need to be a certain degree of transparency when addressing the sustainability concern with customers and brand owners; these groups will want proof that the materials they are using are safe for the environment.
“While Flint Group will not disclose specific formulation and manufacturing details, there are certain aspects we are happy to share with customers – such as the source of our raw materials, our goal being that all are sustainably sourced; the bio-renewable content of materials used in our ‘sustainable’ branded products; the generic make-up/chemistry of our inks and coatings; and the health, safety, and overall environmental impact of our products,” Klemesrud noted. “Flint Group is encouraged by the heightened level of interest in the environmental impact of inks and coatings on packaging and more than willing to discuss these topics with customers directly.”
“All our customers can review and request our technical and safety data sheets for any product we deliver to them,” Robert O’Boyle, senior key account manager, sustainable products, Sun Chemical, reported. “Sun Chemical often works with CPG’s product stewardship groups to ensure compliance with their individual requirements. Such requests are becoming more and more frequent.”
Siegwerk CTO Ralph Detsch said that to enable the proper management of the compliance work along the packaging chain, Siegwerk is committed to providing all necessary information regarding the composition of inks.
“In detail, this includes information on all relevant migrants, whether originating from intentionally added substances (IAS) or non-intentionally added substances (NIAS),” Detsch pointed out. “The information is provided by Statements of Composition (SoCs). Here, Siegwerk is following a strategy of transparency aimed at making sure both converters and brand owners have all relevant information needed to fulfill their requirements.”
Bernd Groh, hubergroup's product management packaging inks offset Europe, said that hubergroup offers all of its food packaging customers and their brand owners a Statement of Composition (SoC) as a declaration of conformity regarding the standard/regulation to be applied.
“This SoC contains information about migrants, listings and restrictions,” Groh said. “All substances with the potential to migrate used in our formulation or known to be present will be listed in this SOC, starting by naming the CAS-No ending by the maximum amount in the dried ink film.”
Rebecca Lipscomb, assistant director of global regulatory affairs for INX International Ink Co., noted that INX receives requests for confidential business information (CBI) on its ink formulations.
“This has become more frequent in the last year,” explained Lipscomb. “Oftentimes we find that the proprietary information was not necessary to answer the actual question. Having face-to-face discussions or phone conferences with our customers often assists us in determining what is actually needed. If it is determined that some amount of CBI would be necessary to come to a resolution, we work with the labs or consultants of our customers to complete the request.”
“We do receive requests for disclosure of proprietary information on our ink formulations,” said Evan Benbow, director of R&D at Wikoff Color. “We have internal practices for handling the requests and do so on a client-by-client basis.”
“This is something that we have seen a definite increase in queries for, but it can be very difficult to disclose,” Simon Daplyn, marketing manager, Sensient Imaging Technologies, observed. “As an ink manufacturer, the value of our products is in their complex chemistry and our ability to select materials and processes that enable the best possible quality and results for our partners. While we do provide some disclosures, for example, safety data and product labeling, plus certificates of analysis for some applications, the fundamental intellectual property is held to ensure that we deliver the highest-quality, best-value solutions for our partners and customers.
“However, we do provide reassurance to our clients by ensuring that our products are always in-line with the latest compliance regulations,” added Daplyn. “We have products that are compliant with the OEKOTEX ECO PASSPORT and Zero Discharge of Hazardous Chemicals (ZDHC) regulations, among others, to make sure that we are up-to-date with the very latest sustainability requirements across the industry.”
George Fuchs, NAPIM’s director of regulatory affairs and technology, said that requests for detailed compositional data are becoming an increasingly common issue in the US.
“In other geographic regions outside the US, it is either a requirement or a common industry practice,” Fuchs added. “Within the US, this type of disclosure of compositional information generally occurs only under a legally binding, non-disclosure agreement between supplier and customer.”
Deanna Klemesrud, global marketing director-brand & promo, packaging inks and resins for Flint Group, said that there does need to be a certain degree of transparency when addressing the sustainability concern with customers and brand owners; these groups will want proof that the materials they are using are safe for the environment.
“While Flint Group will not disclose specific formulation and manufacturing details, there are certain aspects we are happy to share with customers – such as the source of our raw materials, our goal being that all are sustainably sourced; the bio-renewable content of materials used in our ‘sustainable’ branded products; the generic make-up/chemistry of our inks and coatings; and the health, safety, and overall environmental impact of our products,” Klemesrud noted. “Flint Group is encouraged by the heightened level of interest in the environmental impact of inks and coatings on packaging and more than willing to discuss these topics with customers directly.”
“All our customers can review and request our technical and safety data sheets for any product we deliver to them,” Robert O’Boyle, senior key account manager, sustainable products, Sun Chemical, reported. “Sun Chemical often works with CPG’s product stewardship groups to ensure compliance with their individual requirements. Such requests are becoming more and more frequent.”
Siegwerk CTO Ralph Detsch said that to enable the proper management of the compliance work along the packaging chain, Siegwerk is committed to providing all necessary information regarding the composition of inks.
“In detail, this includes information on all relevant migrants, whether originating from intentionally added substances (IAS) or non-intentionally added substances (NIAS),” Detsch pointed out. “The information is provided by Statements of Composition (SoCs). Here, Siegwerk is following a strategy of transparency aimed at making sure both converters and brand owners have all relevant information needed to fulfill their requirements.”
Bernd Groh, hubergroup's product management packaging inks offset Europe, said that hubergroup offers all of its food packaging customers and their brand owners a Statement of Composition (SoC) as a declaration of conformity regarding the standard/regulation to be applied.
“This SoC contains information about migrants, listings and restrictions,” Groh said. “All substances with the potential to migrate used in our formulation or known to be present will be listed in this SOC, starting by naming the CAS-No ending by the maximum amount in the dried ink film.”
Rebecca Lipscomb, assistant director of global regulatory affairs for INX International Ink Co., noted that INX receives requests for confidential business information (CBI) on its ink formulations.
“This has become more frequent in the last year,” explained Lipscomb. “Oftentimes we find that the proprietary information was not necessary to answer the actual question. Having face-to-face discussions or phone conferences with our customers often assists us in determining what is actually needed. If it is determined that some amount of CBI would be necessary to come to a resolution, we work with the labs or consultants of our customers to complete the request.”
“We do receive requests for disclosure of proprietary information on our ink formulations,” said Evan Benbow, director of R&D at Wikoff Color. “We have internal practices for handling the requests and do so on a client-by-client basis.”
“This is something that we have seen a definite increase in queries for, but it can be very difficult to disclose,” Simon Daplyn, marketing manager, Sensient Imaging Technologies, observed. “As an ink manufacturer, the value of our products is in their complex chemistry and our ability to select materials and processes that enable the best possible quality and results for our partners. While we do provide some disclosures, for example, safety data and product labeling, plus certificates of analysis for some applications, the fundamental intellectual property is held to ensure that we deliver the highest-quality, best-value solutions for our partners and customers.
“However, we do provide reassurance to our clients by ensuring that our products are always in-line with the latest compliance regulations,” added Daplyn. “We have products that are compliant with the OEKOTEX ECO PASSPORT and Zero Discharge of Hazardous Chemicals (ZDHC) regulations, among others, to make sure that we are up-to-date with the very latest sustainability requirements across the industry.”