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Flexo Sustainable : Year End 2011
that food packaging should not transfer materials to the pack- aged goods in quantities that bring about a change in nature, substance or quality of the food, and must not be injurious to health. In addition, producers must operate using "Good Manufacturing Practice" (GMP) as defined in EU Regulation (EC) No 2023/2006. More recently, Swiss Regulatory Authorities have intro- duced an "Ordinance," which specifically outlines lists of raw materials that can be used in food packaging inks. Each listed substance will eventually have a specific migration limit (SML) against which the down-stream stakeholders are expected to assure compliance. While technically this "Ordinance" only affects inks and packaging within Switzerland, its effects have been keenly felt throughout Europe and beyond. In fact, many customers and brand owners outside of Switzerland expect inks and coat- ings to comply with these requirements. At the start of 2011 the German Authorities also declared their intention to implement their own National Ordinance on inks for food packaging. Both sets of legislation are fully anticipated to form the basis of European-wide legislation in coming years. ROLE & RESPONSIBILITIES According to the UK Food Standards Agency, "The pack- aging designer, manufacturer and the food manufacturer that distributes the product are responsible for ensuring the requirements of the regulations are met AND for ensuring appropriate selection of materials for the intended end use of the packaging." The reason for this delineation is that the ink manufacturer does not control the selection of inks and coatings for each print specification nor the press production and environmen- tal conditions. Simply printing with low migration inks and coatings does not ensure compliant packaging; appropriate good manu- facturing printing protocols also have to be adhered to. It is strongly advised that the industry adhere to all published guidelines and regulations covering food packaging and to use only appropriately selected inks and other consumables. CHOICES & NECESSITIES Printing compliant food packaging is often seen as a minefield of complex legislative decisions, however, the brand owner, print specifier and print converter have some simple choices to make. A risk assessment should always be com- pleted at the initial stage of the packaging concept design, starting with the package designer and the brand owner. If a migration risk is anticipated, then the package either needs to be tested to prove its migration performance and appropriate steps taken to reduce the risk, or low migration inks and coatings should be used to avoid any worries. • If the testing route is chosen, and it is proven that appro- priate barrier performance is provided by the substrate, then the designer has a choice of using standard inks and coatings or "intermediate" migration solutions. • If unacceptable migration is present, then it becomes nec- essary to either design in a functional or absolute barrier to migration or use low migration inks and coatings. The economics of the choices a printer needs to make with regard to migration, however, pose another challenge com- pletely. Weighing up which route is the most cost effective can be complex, but the bottom line is that the whole of the pack- aging supply chain, from brand owner to packer filler, needs to work together to ensure safe packaging for the consumer. By and large, printing and converting companies are expert in selecting appropriate procedures and practices in An example of food packaging that would typically need the use of low-migration inks. www.flexomag.com YEAR-END 2011 Sustainable FLEXO 11