Delegates represented the whole packaging chain
Under the title ‘Managing the Migration Myth’, the British Coatings Federation pulled in an impressive number of attendees to its packaging summit in late November. Neel Madsen reports.
Held on 28 November at Sketchley Grange Hotel, in Leicestershire, the BCF’s seminar on ink migration was a roaring success with 130 people attending. Aimed at the entire food packaging supply chain, attendees included printing inks and substrates manufacturers, converters, brands, retailers and associations, who all came together to listen to presentations debating food packaging safety and concerns over the potential for ink components to migrate into food.
Before the event, BCF chief executive officer, Tom Bowtell, explained that the focus would be on understanding how the industry can collectively manage these concerns, by looking at best practice across all packaging substrates.
In his welcome address, president Nick Smith also spoke about cooperation, saying, ‘The high attendance at our seminar today reflects the importance of the topic which we will be debating. The risk of ink migration is minimal if everyone in the entire supply chain play their part and we all work together to address the concerns.’
Regulatory demands
After a brief introduction from the sponsors, Chris Whitehead, who is the BCF’s printing inks consultant, outlined the regulatory demands that are put on the industry from the EU.
The main piece of EU legislation is the Food Contact Materials Regulation 1935/2004 (the Framework Regulation), which requires that ‘food contact materials must not transfer their components into food in quantities that could endanger human health, change food composition in an unacceptable way or deteriorate its taste and odour.’
Mr Whitehead drew attention to article 3, which defines good manufacturing practices (GMP) as ‘those aspects of quality assurance which ensure that materials and articles are consistently produced and controlled to ensure conformity with the rules applicable to them and with the quality standards appropriate to their intended use […].’
Emphasising that the seminar was addressing migration issues arising from printing on the non-contact side of food packaging, he pointed out that although the framework regulation does not apply to inks and coatings, it is important to acknowledge that once it is printed, the ink becomes part of the packaging. All food contact articles must have a declaration of compliance (DoC), which again does not apply to inks printed on the non-contact side, however, according to Commission Regulation 10/2011 on plastic materials and articles intended to come into contact with food ‘adequate information should be provided to the manufacturer of the final plastic article that would enable him to ensure compliance […]’.
President of the BCF, Nick Smith from SunChemical, welcomed the audience
Other relevant legislation include Regulation 2023/2006 on good manufacturing practices for materials and articles intended to come into contact with food, and the Swiss Ordinance, which although not applicable outside Switzerland, is often used as a standard, and in effect contains a positive list of ink raw materials and components thereof.
Mr Whitehead also discussed barriers to migration. The only absolute barrier materials are glass and metal, but some structures can act as ‘an effective functional barrier’. The latter must be proven by testing and worst case scenario calculation with the substance that has the potential to migrate.
Retail packaging
The view of the retailer and the brand owner came from keynote speakers from Waitrose and Danone.
Alison Lord has worked for a number of the major supermarkets and brands. She has been at Waitrose for five years as their chemist. She described the challenges retailers face in terms of compliance with food packaging regulations and ensuring good manufacturing practices throughout the supply chain.
The high number of new product developments and turnover of products also put a lot of demands on retailers, while incidents such as the recent horsemeat scandal further put pressure on the industry and influence the consumers’ perception of risk. Waitrose has a number of policies in place and uses sector specific supply chain checklists to ensure product safety.
Speaking of the demands that the new EU Food Information Regulation 1169/2011 (FIR) are putting on retailers, she said, ‘The irony is that while everyone is trying to reduce packaging, the EU is introducing new legislation that requires more information on the packaging which may have to be enlarged to accommodate this. Pretty much all our packaging will have to be changed.’
Ms Lord explained that the resources to manage compliance with regulations vary between their suppliers, depending on size, and that each technical manager at Waitrose has hundreds of products in their portfolios. She said, ‘Packaging compliance is just one of the many demands that are put on our technical managers, so the more support we can get from the packaging industry the better.’
She continued with what became the common theme of the day, ‘We all share the common goal of food safety and compliance. In order to achieve this, we need open dialogue and the sharing of knowledge. Each link in the chain must take ownership and responsibility for their part in the process.’
Her final plea was for all suppliers to maintain good manufacturing practices even when the deadline for FIR compliance nears and everyone will be under added pressure.
The speakers included Vince Dean, RPC Group; Jay Betton, UPM Raflatac; Andrew Barnetson, CPI; Alison Lord, Waitrose; Chris Whitehead, BCF; James Mellman, Danone; Dr Martin Kanert, EuPIA; John Dixon, Flexible Packaging Europe; Nina Happonen, MetsäBoard; Paul Hunt, SunChemical; Lee Metters, Domino Printing Sciences
The age of suspicion
Packaging specialist in advanced medical nutrition with Danone, James Mellman, spoke about ‘packaging in the age of suspicion’, and outlined the many crises and alerts the industry has had to deal with in recent years. The company has staff dedicated to ensure compliance with legislation, and he echoed Alison Lord’s sentiment that quality and regulatory compliance must be managed throughout the whole supply chain.
Pointing out that information needs to flow both ways, an audience member commented that not all retailers/brands divulge enough information about the intended use of a product, and so ‘we are in effect manufacturing blind.’ Mr Mellman said that Danone is well aware of this need and does supply that information for all of its products.
The trade association
The European Printing Ink Association (EuPIA) gives guidance to its members assisting them to contribute their respective share to the legal compliance of the final packaging, explained the trade association’s executive manager, Dr Martin Kanert.
The association’s exclusion list for printing inks and related products should be the first port of call. This is frequently reviewed by the EuPIA technical committee and ‘applies to all types of inks for all types of printing processes for all types of applications.’
The association also offers a model statement of composition (SoC) and a customer guidance note, which includes an example of the process chain involved in the risk assessment of the migration of substances from inks into food. These are available on its website along with the guideline and general information on packaging inks.
Under the auspices of Food-DrinkEurope, a packaging ink joint industry task force (PIJITF) has been set up, of which EuPIA is a member. The task force includes representatives from the printing ink industry, packaging manufacturers and food producers, and was established with the goal of ensuring ‘the production of safely packaged food and the maintenance of high levels of consumer confidence in food safety.’
It has produced an explanatory note on the assessment of migration potential from food packaging inks and its dependency on the packaging structure, which contains a definition of low migration inks: ‘A low migration ink is an ink designed for use on food packaging that is formulated using selected components which should ensure that migration from the resultant printing ink film will be within accepted migration limits, provided that the packaging structure is suitable, and the packaging ink is applied under good manufacturing practices in accordance with guidance given bythe ink supplier for the intended application.
‘The use of such inks should be supported by indicative analytical testing and/or relevant worst case calculations.
‘As a result assuming correct application and appropriate packaging type any migration from the printed packaging should be within currently accepted limits.’
Testing
Solutions from ink manufacturers were presented first by Dr Hans- Peter Seyer, from Flint Group, who gave an overview of the company’s conventional and UV cured offset products. He concluded that the production of food packaging requires specialist knowledge and cooperation between all participants. He reminded the audience that the ink and coating supplier is also there to give advice and guidance.
Next Paul Hunt from SunChemical covered flexo and gravure printing. He said that a good starting point for determining whether a substance is of concern in a packaging structure is to do a ‘worst case calculation’. This assumes that all components will migrate into the food. The amount of migration is then measured to see if it falls below the specific migration limit (SML) for that substance. If it does, the substance is of no regulatory concern. To perform the calculation, the concentration of the component in the dried ink film, the ink film thickness, the packaging surface area and the food weight must be taken into consideration. If the substance cannot be excluded by this method of testing, migration testing must be performed. This involves incubating a migration cell with a food simulant and then testing using analytical equipment.
BM Trada took part in the table top exhibition
Mr Hunt said, ‘For energy curing inks doing worst case calculations is of more limited use as before curing most of the components are present at above the SML, and the curing process is not within the control of the ink maker. The term ‘low migration inks’ has therefore been introduced to denote those inks that when applied and cured according to good manufacturing practice, result in a dried ink film that complies with all of the regulatory migration limits.’
He also emphasised the important role each link in the chain plays to ensure compliance. Raw material suppliers provide substance information in their raw materials to ink manufacturers who in turn write statements of composition (SoCs) indicating potential migrants. The SoCs are then used by the converters and packaging manufacturers to determine whether the final packaging is compliant so they can provide declarations of compliance to the brand owner. ‘If correct process is followed then migration from inks can be controlled and regulated,’ he concluded.
Industry guidance
The 72 members of Flexible Packaging Europe (FPE) produce about 75% of European flexible packaging turnover. In cooperation with the International Confederation of Paper and Board Converters in Europe (CITPA), the association has formulated a code for good manufacturing practices for flexible and fibre-based packaging for food, which John Dixon, director of regulatory affairs, described as a management tool providing the methods by which the goals of compliance with regulation can be attained.
Mr Dixon explained that it is not practical for each converter to test every single product individually, and therefore a rational testing plan must be developed. This can employ either the ‘family’ approach, ie testing an appropriate selection of a defined group of products, or the ‘building block’ approach, which uses the compliance of a number of products or components to infer the compliance of other products made with different combinations of similar components.
In his presentation, Andrew Barnetson, who is director of packaging affairs at the Confederation of Paper Industries (CPI), agreed with the earlier speakers about the importance of communication and liaison, and praised the BCF’s initiative.
The CPI, which has 67 members, also offers an industry guideline for the compliance of paper and board materials and articles for food contact. It works closely with the Food & Drink Federation (FDF) in the UK.
Mr Barnetson said, ‘Through the FDF, the food packaging value chain in the UK can unite and present one voice to the Food Standards Agency and the retailer. This kind of event is exactly what we need. We don’t do enough of these, but this is certainly a good start.’
Conclusion
The issue of migration is of course vital to all printing inks manufacturers as evidenced by the large number in attendance, which along with sponsors Stehlin Hostag Ink UK (huber group), Flint Group and SunChemical, included ColorGen, European Printing Inks, Fujifilm Specialty Ink Systems, Gardiner Colours, INX International, Mirage Inks, Paragon Inks, Pulse Printing Products, Pulse Roll Label Products, Siegwerk, Vision Inks and Wikoff Color. There were also a large number of adhesive and coatings manufacturers, as well as brands and printers, present. Also in attendance were the Food Standards Agency and the Food & Drink Federation, while sponsors BM Trada, the certification specialist company, and Stort Chemicals, took part in the table top exhibition.
There was no doubt that the common theme of the day was the importance of communication and full disclosure. Although the end responsibility for a product lies with the manufacturer that brings it to market, it is paramount that all parties of the food packaging supply chain provide sufficient information to ensure the safety of each product.
Nobody wants to give consumers any cause for concern and the media the opportunity to blow issues out of proportion.
Mr Bowtell concluded, ‘There has been considerable coverage in the press on migration and risks to packaged food in recent years, and our Food Packaging Summit has shown that by working together, the food packaging supply chain is demonstrating that it is managing the issue competently and professionally. I am delighted it was such a success and we plan a follow up event next year.’
