Food safety has been a topic of discussion among the packaging industry stakeholders for a while now, with everyone, from regulatory agencies to ink and substrate manufacturers to converters waking up not just to the importance of safe packaging for food items, but also the legal implications of it.
Ink manufacturer Siegwerk has been on the forefront of this, especially in India, as the company proactively banned the use of toluene for solvent-based inks at its Bhiwadi-based manufacturing facility, over two years ago, much ahead of the regulatory ban on toluene in India.
“Siegwerk has established itself as a market leader for packaging inks, and also in the field of the sensitive food contact applications,” says Jörg-PeterLanghammer, head of global PSR and sustainability, food safety measures at Siegwerk in an interview with WhatPackaging?.
When it comes to food items, the basic function of packaging is to keep food fresh and protect it from influences that may deteriorate its quality. The entire value chain of this process involves a delicate balance of chemistry.
Thus, if the package is not manufactured, printed and processed properly, it itself can be a source of chemical contaminants that can migrate into the food. As far as ink is concerned, Langhammer says packaging inks are usually formulated with different chemicals to meet the packaging demands, ranging from resistance against diverse foodstuffs over mechanical and temperature stability, and from deep freeze to retort applications, to facilitate the runnability of the printed material in the industrial packaging machines.
“These chemicals can have toxic and carcinogenic effects if not properly chosen and carefully formulated as suitable food contact material (FCM) inks,” he adds.
The raw material component
So, how does an ink manufacturer ensure safe packaging?
Langhammer says the responsibility begins with the proper selection of suitable raw materials for various packaging applications. “This led us to establish a centrally coordinated process for introducing raw materials used in the ink formulations globally, which is steered from our headquarters in Germany by our global PSR team. This raw material introduction process (RMIP) ensures that each raw material goes through a screening process based on regularly updated specifications, which in most cases are beyond the legal requirements as they are regularly checked in spot-check testing campaigns,” he adds.
The RMIP is complemented by Siegwerk’s formulation guideline, also supervised by the global PSR team. “Like a recipe for cooking, it gives us clear instructions and limitations of use to our ink formulators worldwide to safeguard compliance in whatever region we are operating,” Langhammer explains.
Chemicals should be properly chosen and carefully formulated to be suitable food contact material inks
“Finally, ink formulation, manufacturing and shipment are executed on the basis of good manufacturing practices, either based on existing legislation or following the EuPIA GMP guidelines.” Besides the systematic processes, it is important to collaborate with stakeholders up and down in the supply chain (printers and brand owners) and share relevant information. “We provide information on potentially migrating substances present in our inks via a Statement of Composition (SoC). This allows our customers to assume their shared responsibility in the supply chain and perform the necessary risk assessment on migration and assess the legal compliance of the packaging structures they are manufacturing,” he says. These SoC’s are in line with EuPIA recommendations and are based on current regulatory frameworks.
Role of the value chain
While ink manufacturers are responsible for and can certify the principle suitability of an ink series for food packaging applications, they cannot warrant the legal compliance of the final printed packaging.
According to Langhammer, there are other parameters beyond the control of ink manufacturers, such as the substrate being used, the printing and converting process, type of food packed, and the storage conditions, among others. Thus, Langhammer believes that to avoid problems arising from the use of non-suitable inks, it is important that all parties involved in the industry collaborate. The first step, to clearly define the packaging specifications, is usually the responsibility of the food industry.
Packaging manufacturers and fillers are responsible for the material selection, its permeation, scalping and food contact properties, while the ink suppliers are responsible for supplying safe ink formulations along with transparent information regarding its conversion. These principles of shared responsibility are embedded in a multitude of food contact material regulations worldwide including the European regulations for food contact materials.
State of India regulation
In India, the Food Safety and Standards Authority of India (FSSAI) has given the primary responsibility to food business operators to ensure that the packaging material complies with the Food Safety and Standard (Packaging) Regulations, 2018. Also, the Indian Standard IS 15495 clearly states the responsibility of the printer: “The responsibility of the printer and the converter is to ensure that the food packages are manufactured and stored in a manner by which any preventable transfer of material from the ink or coating to the food contents is avoided, even if such transfer is unobjectionable on the grounds of health, odour and flavour.” Talking about the recent developments in India, Langhammer says that the Indian regulators are taking progressive steps to ensure food safety.
“A few years ago, I remember that FSSAI issued an advisory to ban the use of newspapers to wrap food. It identified that wrapping food in newspapers is a food safety hazard and it also raised concerns over the chemicals in newspaper inks, which can migrate into food. Since then, regulatory agencies in India are progressing in areas of packaging safety,” he says.
FSSAI raised the bar on packaging safety by updating the norms on packaging materials for food wrapping
He also mentions how last year FSSAI raised the bar on packaging safety by updating the norms on packaging materials for food wrapping. It also redefined the food-grade concept for primary packages, regulated inks as per IS 15495, and mentioned a legal obligation for the packaging supply chain among other regulations.
He adds, “And this year, the BIS announcement to ban toluene in food packaging inks is a landmark development. The steps taken by BIS towards promoting food safety are commendable and progressive. They are in line with the global trends of increased consumer safety.” Are these steps enough? Langhammer doesn’t think so. He says, “For India, there is still a long way before one can assure that food packaging is safe by a respective regulatory framework.
A lot of work needs to be done on the regulations in the areas of risk assessment of chemicals, the methodology to review the same at regular intervals, development of analytical techniques, assessment of non-intentionally added substances, and move the standards from a negative to positive list approach.”
Most importantly, a major gap that needs to be fixed is to make sure that the foundation of enhanced legislation is strongly laid and integrated into the supply chain.
“Ensuring packaging safety is a complex process as it involves multiple stakeholders and manufacturers. Most of them need to be self-regulated, as they come from chemical backgrounds, which does not come under the direct scope of FSSAI,” he says, adding that under such circumstances the role of regulators and brand owners becomes much more critical than just passing the specifications down the line. “There is a need for creating forums, where all stakeholders can communicate and align themselves to the requirements laid out by the FSSAI,” he concludes.
FSSAI gives transition timeline for food business operators
Considering the ramifications of the immediate implementation of the new regulation on switching to non-toluene inks for food packaging, FSSAI has given a transition timeline for all food business operators. “Food business operators shall ensure compliance with the revised IS standards by either 1 January or 1 July (2021) as the case may be subject to a minimum 180 days’ transition period from the date of publication of such standards by BIS,” said an FSSAI statement issued in September 2020.