The recipe for changing times
With spotlight on food safety and regulatory framework in the making, Rushikesh Aravkar analyses how packaging can guarantee safe and wholesome food in India
23 Aug 2018 | By Rushikesh Aravkar
Packaged food brands are constantly under scanner over health and safety concerns. A learning lesson in Nestle’s Maggi fiasco, Cadbury’s worm controversy, or for that matter Coca-Cola and PepsiCo’s pesticide row, is that a food safety blunder can not only tarnish brand reputation but also involve massive costs in terms of lost profits, product recalls and customer compensations.
Even though a product can be contaminated because of the unhygienic manufacturing and packing conditions, packaging, whose primary function is to protect what’s inside, is a usual suspect. Therefore, it is imperative for all the stakeholders of the packaging value chain to understand the product contamination potential of a package not only by the environmental contaminants but also from the chemicals present within the packaging especially when it is in direct contact with the food product.
Regulating the pack
In India, Food Safety and Standards Authority of India (FSSAI) and Bureau of Indian Standards (BIS) are determined to ensure food that reaches the consumer is in good condition and void of health risks.
At a recent International Packaging Conclave held on the sidelines of PackPlus 2018, Kumar Anil, advisor, standards, Food Safety and Standards Authority of India, announced that new regulations on printing ink and food packaging material will be in place by July 2019. The FSSAI has released a draft regulation which takes into consideration the carcinogenic effect of ink and dyes and among other things emphasises on prohibiting the use of newspaper for wrapping food and using recycled packaging material for food packaging.
A spokesperson from Huhtamaki PPL, says, “There are standards formulated by Bureau of Indian Standards on packaging safety, however, there is no legal binding to it. It is FSSAI who puts a legal binding on the compliance. The packaging safety regulation is still under ‘Draft Revision’ and not released yet.”
He feels the price-sensitive nature of the Indian market makes it prohibitive for the players operating at the bottom of the pyramid and in the unorganised sectors to comply with the food safety norms. However, he says, “It is the stringent regulation and its implementation that will effectively drive compliance.”
Vinay Nalawade, director, Parakh Group, is sceptical about the draft regulations and the manner in which the framework is being chalked out. Nalawade says, “The FSSAI regulations are very complex and not thought through. What is not banned in developed countries like Europe, USA and Australia are being banned in India. This is a major concern as product safety could be at a huge risk if incorrect packaging material is used.
“I personally think the intentions are good, the execution patchy. The packaging converters should have been on the FSSAI body to decide the final role of packaging in such a way that a converter is comfortable both economically and technically to produce what is being asked to by the competent government authorities. I don’t think consumer health safety can be achieved with current norms as the converters will resort to shortcuts compromising food safety in order to continue doing business in the near future,” says Nalawade.
When it comes to regulations complexity is always a challenge, globally. Jan 't Hart, senior director product management North Asia at Avery Dennison, says, “It takes a food contact expert or someone with extensive study and experience to be able to understand and implement food safety regulations. This also shows that there is a lack of harmonisation: food safety regulations are quite different from one country to another and sometimes conflicting. For example, mineral oil is considered to be a substance of concern in the EU, but a preferred safe food additive in the US. China uses a strict positive list approach for food contact substances whereas the US uses a flexible performance-based approach but also complicated by historical approvals.”
Hart adds, “Cost and timing are difficult topics in this, as for some approvals it can take anywhere from four months to three years to clear all of the regulatory hurdles for one product. To be fair, it can be overcome by taking a worst-case approach and cover multiple products at the same time. Make sure to factor in time for choosing the right approach in product development as it can save time and money.”
According to market research provider, Euromonitor International, the Indian packaged food is a Rs 4.3 trillion market in retail value terms as of 2017 and it is subdivided into four major categories, snacks, dairy, cooking ingredients and staple foods. It is expected to achieve a retail value CAGR growth of 8.19% during 2017-2022.
This healthy growth potential indicates entry of many small and medium-sized players into the food industry. Dilip Radhakrishna, research analyst – food and nutrition at Euromonitor International analyses the two types of players. He says, “One which is compliant of all the safety and security norms as regulated by government bodies. These companies are quite strict when it comes to product quality, hygiene and packaging through well-established packaging companies. They have a good brand image and are among the emerging start-ups sold mainly in major cities across India. They focus on presenting the products in attractive packaging, printing all the health and safety regulations adhered to, ingredients and the benefits after consumption of the products among other information. Hence, their products are priced in between mid-price and premium range. On the other hand, there are the other groups of companies who do not completely follow the food safety norms, have poor packaging of products and are mainly sold in rural and semi-urban regions of India.”
Radhakrishna refers to a study jointly conducted by FSSAI and Indian Institute of Packaging (IIP) in early 2017, which found that majority of the samples did not meet the standards and compromised the safety of the food product.
“The products from such companies are priced economically and are a major threat to both health of consumers and good quality products from other manufacturers. These are usually imitation products of the popular brands of packaged food available in the market,” says Radhakrishna.
Ensuring food safety and being compliant with the regulations is not an easy task. First and foremost, it needs the willingness of the food brand to be compliant. Even then challenges are plenty. The typical food safety concerns in India are missing or there is improper communication of all ingredients information on the packaging; lack of information on allergies or cautionary images to alert consumers about the product; poor quality of packaging – soiled packaging, fading colours and information. Also, ingredients quality, hygiene, and shelf life of the food products.
Defining food safety
Food safety and marketing professionals both have concerns about the safety of the packaged food, as well as the appearance, flavour, odour and other factors affecting consumer appeal. However, while consumer appeal issues still determine the success or failure of a given product, an unsafe container is a public health issue and will affect the future of a food or packaging manufacturer. To counter this issue of hazardous chemicals entering the food products, various regulatory bodies have been set up across the world to monitor and allow the application of certain processes and chemicals.
The draft regulations issued by FSSAI in a notification dated 19 March 2018 suggests that “the primary objectives of packaging are to protect the contents from microbiological, chemical, physical and atmospheric contamination and preserve the food and thereby protect consumer’s health.”
These regulations also specify the requirement for specific migration limit of contaminants from plastic materials intended to be in contact with food. Plus it provides a list of suggestive packaging materials which may be used for packaging of food products.
The Bureau of Indian Standards (BIS) issued a statement about an Alert Panel on printing inks which works on improving the IS 15495. This Alert Panel decided and recommended to include Toluene and few more chemicals into the exclusion list (which in a way means Toluene will be banned to be used as solvent).
Hart says, “We, and our customers, have to deal with regulatory safety requirements of all of our materials. Inks are a big part of this, as well as plastics, adhesives and coatings. All have to be taken into account for complete regulatory compliance as well. Because of the differences in chemistry and the big difference of properties, it is not easy to determine one set of compliance testing. Also, because the packaging material will be different from one application to the other, there is a difficulty to choose one size fits all. Avery Dennison maintains a strict testing regime when it comes to qualifying our materials. This allows us to cover most of the suitable applications. In this way, we make sure our customers know our products are fit for the job and are compliant with the regulatory and industry requirements.”
Niklas Olsson, global brand manager – narrow web, Flint Group, says, “The printing inks have always been designed to have the least impact on human health. But demands are getting stricter and it does require that ink makers do know how to formulate correctly as well as use the production processes that are in line with these demands.”
However, higher cost associated with food compliant inks due to both raw-material selections and careful manufacturing processes seems to be a hurdle for the industry.
Olsson stresses on the need for all members of the packaging supply chain to co-operate with each other and work together with knowledgeable ink manufacturers. “Many printers and brand owners could definitely benefit and challenge market share if they were to adopt a proactive approach to food packaging safety, before legislation takes shape, in the form of making risk assessments already at the design stage, to determine what requirements there are for printing inks and varnishes.”
Back to basics
Olsson dives deep into the science behind migration. He says, “Migration is the transfer of substances from the packaging to the packed food product. Anything in an ink or coating medium with a molecular weight less than 1000 daltons can potentially migrate. Those over that weight that do migrate pose no health risk as they pass straight through the body without being absorbed.”
The potential migrants are plasticisers from plastics or inks, monomers from plastics or coatings; solvents, cleaning chemicals, oils and greases; and low-molecular-weight components from substrates, adhesives or inks, such as photoinitiators.
Olsson explains, “The sources of migration fit into four categories - inks or coatings, environment, substrate or barrier material, and the printing and converting process. Migration occurs in four ways: penetration migration – through the substrate to the reverse side of the print; set-off migration – from the printed side of a substrate to the reverse side of the substrate while stacked or stored on a roll; vapour-phase migration – evaporation of volatile compounds when heated; condensation extraction – condensation of critical compounds when cooked or sterilised.”
Therefore all the major ink manufacturers have food packaging compliant inks in their portfolio, which are also called low migration inks. However, Olsson points out that there is no standard definition of ‘low migration’, though it is vital to remember that a low odour product will not necessarily show low migration, and low migration does not mean 'no' migration.
“Having said that the low migration UV inks and varnishes are developed so that when correctly applied and cured, onto the correct choice of packaging substrates, the legal migration limits can be met. Nevertheless, no ink or varnish supplier can guarantee that the formulated migration levels will always be achieved in practice, as so many practical factors have an impact,” says Olsson.
One of these factors is the UV lamps used for ink curing. Marcus Greenbrook of GEW, says, “Curing of low migration UV inks is similar to any other UV ink. When high energy UV light hits the photoinitiators, cross-linking and polymerisation begin. With low migration inks, this can be a harder to cure and in some cases requires higher UV output. It is important for the packaging converter to maintain the UV curing system. Some conscious converters go to an extent to replace UV lamps in less than 500 hours of usage. Again with GEW multi-point UV monitoring (mUVm) system, the live reading will help to determine when to change lamps.”
Jayachandran Nair, business head, flexible laminates for India, Middle East and Africa at Henkel Adhesives says migration from adhesives is different to that of plastic films.
He explains, “The adhesive layer is generally much thinner than the film. The polyurethane (PU) adhesives are reactive and when fully cured contain almost no free molecules. The inner plastic film acts as a functional barrier. However, the reactive nature of PU adhesives can lead to a formation of primary aromatic amines if the adhesive is not properly employed.”
Nair delves on the chemistry which raises the concern for food safe materials. He explains that a simple polyurethane (PU) reaction which results in the urethane linkage also results in components with free isocyanates. These free isocyanates in the presence of moisture form carcinogenic primary aromatic amines.
Nair says, “A proper decay of these primary aromatic amines results in the formation of a safe product. In case of an unsteady or unfinished decay, the by-product in the packaging will be hazardous.”
Nair highlights key food safety regulations namely the EU, FDA and the Chinese GB regulations. “Food safety regulation is a global phenomenon. It has reached a point where global food companies are creating their own global standards.”
He adds, “Henkel Adhesives follows the EU regulation which is widely regarded as the most stringent regulation.” Nair shares Henkel’s belief in the triple food safety process. “Proper focus is given to supplier assessment, analytical assessment and toxicological assessment,” says Nair.
In order to ensure the safety of food packaging adhesives, Henkel has implemented a strict raw material selection process. The basis is the supplier questionnaire.
Among others, the questionnaire requires, compliance with food contact criteria; a clear commitment of the supplier with respect to maximum concentration levels of components and NIAS (Non-Intentionally Added Substance); a clear commitment of the supplier to promptly notify Henkel about any change in the provided information before the change occurs and as soon as any new information about the product is known.
The traditional definition of food-grade paper and board for packaging is one, which is suitable for food contact, free from contaminants and does not alter the organoleptic properties of the food that it packs.
SN Venkatraman, vice president - marketing at ITC's Paperboards and Specialty Papers Division, explains, "At ITC PSPD paperboards for food packaging are carefully designed keeping the end user in mind: only virgin fibers from sustainably managed plantations are used or if recycled fibers are used then the board is coated with a food compatible barrier. Secondly, the bleaching is elemental chlorine free and keeps the board free from dioxins and furans. The process also ensures that there is no presence of any heavy metals."
When asked about the pitfalls to be avoided while converting food-grade paperboard to cartons or cups, Venkatraman, says, "The conversion from paper and paperboard to final form must follow some Good Manufacturing Practices guidelines. The BRC Global Standard checklist is a good place, to begin with. We have created an extract of this and assist converters in implementing these practices. It helps in determining the hygiene category such as high or low risk and then proceeds with corrective actions. Converters who conform to these become a part of our Indobev Champions Network."
He adds, "If recycled fiber-based boards are used then a suitable barrier to mineral oil migration has to be imparted to the board. The print is protected with aqueous coatings and UV varnish is usually avoided due to its odour."
Ultimately food safety is the brand owner’s responsibility, but it is the packaging converter who is the change-maker. The packaging converters have to join hands with their upstream suppliers and invest significant financial and intellectual resources to develop solutions that are in line with the regulations being planned and at the same time affordable for the buyers.
Today, Indian packaging converters have their hearts in the mouth as they seek clarity on packaging regulations whether it is related to changing regulatory framework to achieve food safety or ban on certain kinds of plastic packaging to achieve sustainability.
Nalawade of Parakh Group says, “We have to understand new development is a long process till a packaging film is produced and goes to the final consumer, and it has to pass at all stages in between. We have conducted a lot of trials and developments have happened in the last two years to get onto a sustainable package which can suffice many points from the brand manager’s perspective. We are working closely and in confidence with the end-user companies in all developments and trials.”
As a consumer, one should not mind paying an extra penny if one knows that not only the chocolate which one eats but also the packaging which wraps the chocolate are safe.
As the regulatory framework comes into place, we need a change of mindset towards food safety. Nair quotes a food major who says, "If you supply to a food company, you are no longer just a packaging firm, you are a part of the food industry. We treat food packaging with the same food safety rigour as food ingredients."