Siegwerk webinar on the legal obligations towards ink safety

The safety aspects of packaging inks are gaining attention worldwide due to the presence of several substances with potential toxicological profiles, such as mineral oils, toluene, PFAs, benzophenone and several others. Globally, the discussion around the subject is leading to more awareness in the market which is subsequently pushing the regulators to further raise the bar on packaging safety. The regulations worldwide are getting stricter and harmonised, pushing the supply chain partners to adhere to the new norms. 

The Food Safety and Standards Authority of India (FSSAI) has raised the bar on packaging safety in its recent food packaging regulations. The Bureau of Indian Standards (BIS) has revised the standard IS 15495. Siegwerk, being the market leader in India for food grade inks made a sincere attempt to create awareness in the market with support from the Food Safety and Standard Authority of India as well as Bureau of Indian Standards.

Harish Kumar RK, assistant director, Science and Standard Division, FSSAI, was the first speaker for the session. He highlighted the roles and responsibilities of FSSAI and detailed the process of drafting a regulation at FSSAI. 

He said the industry has long been focused on food products, but not on the safety aspects of the packaging/ packaging material and for this reason, there were concerns and this were addressed by FSSAI and for the same reason the FSS (Packaging & Labelling) Regulation, 2011 was split into Packaging Regulation (in effect since 2019), Advertisement & Claim Regulation and Labelling & Display Regulation to give due importance to Packaging. 

The FSS (Packaging) Regulation was notified on 24 December 2018 and was enforced from 1 July 2019. The FSSAI regulation is mandatory for the food business operators (FBOs) and manufacturerers of materials to ensure compliance. 

Harish then explained how material-wise requirements have been specified for paper and board, glass, metal and metal alloys, and plastics. He added that in the regulation, definition of food grade has been incorporated, and inks have been regulated as per IS 15495, among several other changes. 

He said the recent amendment on use of recycled plastics in food packaging (which is currently only limited to rPET) and the process around the approval of use of recycled plastics. 

Harish concluded his session with three key messages:

1 Need for an integrated approach: Regulatory information/knowledge to be shared among the supply chain partners 

2 Safe packaging: Contributes to food safety and responsibility lies with FBOs and material manufacturers 

3 Packaging regulation is a mandatory regulation and needs adherence to ensure compliance 

Sagar Singh, deputy director, Chemical Division, BIS, was the next speaker on the panel. He said the standard IS 15495, which is now mandated by FSSAI, is a standard created by the Bureau of Indian Standard. He said although printing inks constitutes a small part of the package, its impact is immensely significant and the next big issue in sustainable packaging is printing inks.

He said the standards created by BIS are not static but dynamic in nature and recently the standard IS 15495 was revised by incorporating chemicals like toluene and certain phthalates. He also mentioned that the current ink standard is a negative list standard which restricts certain chemicals in ink formulations.

He added that the endeavour of BIS has been to adopt a positive list standard approach where only those chemicals will be prescribed which will be non-hazardous. He elaborated the standard IS 15495, citing the detailed requirements for external packaging, disposables and immediate food wrappings. 

The standard was first created in 2004 to assist ink manufacturers produce inks for food packaging and has been revised providing details about the revision. The work on the standard is ongoing and it includes NIAS, inclusion of mineral oil and cobalt carboxylates in Annex- A, xylene and methylcyclohexane in film printing of food packaging, some photo initiators in Annex- A. 

Singh elaborated on the concept of NIAS, and concerns associated with it.

BIS is also working on developing a new standard for eco-friendly inks. 

He also spoke about the digital initiatives taken by BIS to promote industry participation, which includes the launch of the Standardisation Module, which gives the provision to provide the comments on standards, provision to become a member in the standards committee.

The speaker for the session was Jatin Takkar, head – product safety and regulatory, Siegwerk India. He broadly spoke about the implementation of packaging safety to ensure consumer safety. He said ensuring packaging safety is complex as there are different pillars which the food and packaging industry has to manage. This includes regional regulations and brand owner requirements, and complex packaging supply chain as well as manufacturer commitments. The regional regulations are different in terms of their structure and associated details and are further supplemented by the brand owner requirements, which makes it complex for the supply chain to ensure compliance. Apart from this, the regulatory status of the chemicals may change over time, which is yet another challenge which needs to be mitigated by the commitment from the manufacturer itself. And finally, the complex packaging chain with multiple stakeholders, some with expertise on chemicals safety while others with expertise on food safety. 

Takkar also mentioned how packaging safety can be ensured by taking different measures across the supply chain. These include:

1 Developing understanding of packaging safety and associated legal obligations 

2 Developing capabilities for creating specifications and performing risk assessment 

3 Promoting transparency and integration across the supply chain 

4 Developing systematic processes and mechanisms around right vendor selection 

5 Deploying the monitoring as well as the auditing protocols 

Takkar also emphasised upon the correct documentation practices that demonstrate packaging safety. He said currently a lot of certifications/ self-declarations issued by the manufacturers are not adequate enough to demonstrate the compliances, however, are well accepted by the brand owners because there is limited understanding on packaging safety, associated legal obligations and systematic processes that are required to demonstrate the compliances. He shared examples of the correct certification methodology and explained all clauses that need to be captured in an authentic declaration. 

He concluded his session explaining the reasons for creating more awareness on the packaging safety primarily from the brand owners and regulators’ end as well as the need for harmonising the Indian standards with the best available standards globally.