Smithers: Can you provide a brief update on the planned EU measure on Printed Food Contact
Dr. Nick Ivory: There has currently been no notable progress from the authorities on the drafting of the proposed pFCM measure. The food packaging supply chain have continued to work on their proposal for the pFCM measure and to lobby the relevant authorities. The next step will be for the European Commission to recruit a consultant, who will be responsible for producing a draft legislative proposal.
Smithers: What are the implications for ink manufacturers like Sun Chemical?
Dr. Nick Ivory: The implications for ink manufacturers will be that there will be a single European legislation
on the permitted migration levels from printed food packaging. At the moment the only legislation in place is the Swiss Ordinance which the packaging industry have been using as the de facto standard, along with some brand owner guidelines, like Nestlé’s “Guidance Note on Packaging Inks”, to work to. This will provide a clear pathway for everyone to follow and will remove any remaining doubts about what the expectations of food packaging
performance in Europe are.
Smithers: What are the implications for packaging converters and printers?
Dr. Nick Ivory: It will provide the printers and convertors with a clear guideline for them to work to that will
be applied across Europe. As above they in the most part have been working to meet the migration limits set out in the Swiss Ordinance, so working to the pFCM measure will in all likelihood not bring a great deal of change to what they are currently doing. The industry proposal for the use of risk assessment in the pFCM measure however will provide an added level of confidence in the use of compliant products to produce food packaging.
Smithers: How does the proposed EU position on Inks compare with food contact regulation for inks
around the globe?
Dr. Nick Ivory: At the moment the only enacted legislation is the Swiss Ordinance; the proposal that the
industry has prepared to submit to the European Union will be similar in its approach, with migration limits for fully evaluated substances determined by the level of toxicological data available for the material concerned. The proposal is that materials currently listed in the Part B annexes of the Swiss Ordinance, along with any other “Not Evaluated” materials which can migrate, should be risk assessed for suitability. There is other food packaging legislation being developed in China, India and Australia/New Zealand, but these are in draft form currently and it is not clear how they will compare to the final version of the EU pFCM measure . However they will in all likelihood contain definitions of what level of migration of ink components is permissible into food from packaging.
Smithers: What are you most looking forward to about the conference?
Dr. Nick Ivory: A chance to meet others from around the food packaging supply chain who face the same challenges as we do in Europe and to pick up more information about how they think legislation in their own countries is likely to develop and what the basis for control might be.