Statement on Printing Inks and Food Packaging
From the onset, it is essential to distinguish between package designs where the ink is intended to come into direct food contact and those where direct food contact between the printing ink film and the foodstuff is neither intended nor expected. An example of inks with no direct food contact is the printing on plastic tubs for yogurt and margarine.
INKS FOR DIRECT FOOD CONTACT
There are four agencies in North America that have regulations affecting the use of printing inks for food packaging applications.
In Canada, both Health Canada (Health Protection Branch) and the Canadian Food Inspection Agency deal with food packaging issues. The Canadian Food Inspection Agency (CFIA) enforces packaging requirements with respect to federally regulated packaging facilities. Health Canada sets standards and evaluates food packaging with respect to the standard. Although it is not mandatory, the Health Protection Branch recommends that food packaging companies obtain a letter of non-objection for any packaging that may have direct contact with food. This letter can only be obtained after properly designed extraction tests have been made using the materials that represent the foodstuff that is to be packaged. If such extraction tests are not done, then Health Canada, to the best of our knowledge, will assume a worst-case scenario in which the majority of the ink components are assumed to migrate into the food in significant quantities. In addition, they will request toxicological data as described under the section below on "no direct food contact".
The regulatory body in the United States is the Food and Drug Administration (F.D.A.). The F.D.A. does not approve specific products (i.e. printing inks) for direct or indirect contact with food. Their sole concern is with materials that may become, either by default or design, food additives. They also rely on either properly designed extraction studies or expert testimony, before determining the food additive status of a printing ink.
The other agency in the United States is the Department of Agriculture (U.S.D.A.) The U.S.D.A. regulates the packaging materials used primarily for meat and poultry products. It is important to note that the U.S.D.A. stresses that the responsibility for providing guarantees to food packers rests with the converters who provide the finished packaging material. If direct contact between the foodstuff and the printing ink is intended, then the U.S.D.A. follows the same food additive regulations as the F.D.A.
NO DIRECT FOOD CONTACT
In Canada, when "no direct food contact" with the ink film is intended, there is no need for a food packager to obtain a letter of non-objection from Health Canada, provided the following requirements are met:
- The package design should incorporate a functional barrier between the foodstuff and the final ink film;
- The inks must be properly and completely dried or cured after printing, such that the print does not set-off or mark during the stacking or nesting of the packages prior to filling with food.
The previously mentioned functional barrier concept for "no direct food contact" is also recognized by the F.D.A. and the U.S.D.A.
CONCLUSION
The issue of "direct food contact" and "no direct food contact" of printing ink for food packaging application refers to the toxicological properties of a printing ink. Of equal importance in some applications, are the odor and taint properties of the printing ink being used. There is not necessarily any direct relationship between toxicological, odor and taint properties. The latter should be determined independently for a given package design and product.
For further information contact:
Peter C. Berry, PH.D.
Director of Quality and Sales
Hanes Erie, Inc.
Peter Berry
(814) 474-1999