Printing inks on food contact materials, EU rules are being worked on


The safety

of printing inks on materials in contact


foods will finally be the subject of common EU-wide rules. La

european commission



announced the

Starting work on harmonization of rules. With p

riority to prints on paper and cardboard that wrap food


The stimulus comes from the Germany, which worked for over a year to a specific legislation national, which traces a law already in force in Switzerland.

La grand part of the member states EU is to date without regulations to guarantee the safety of inks used in food packaging.

A European level, printing inks must meet the only requirements general of which to the framework regulation at Food Contact Materials (1) e the one on the related GMP, Good Manufacturing Practices) (2). Once compliance with these regulations is established, printing inks can be placed on the market throughout the EU, remaining subject to any national legislation and To the principle of mutual recognition.

The kingframework regulation definisce a principle general security, specificndo That food contact materials and articles must come manufactured in accordance with the GMP so that the samei do not transfer their constituents to foodstuffs in such quantities as to pose a danger to human health, result in an unacceptable change in the composition of foodstuffs or its organoleptic properties.


he GMP regulation

in turn Applies to all food contact materials at all stages of production, with the not inconsiderable exception of the manufacture of substances of base. And it defines a criterion,

according to


practitioners should establish, implement and maintain an effective and documented quality assurance system


In good substance the GMP represent the set of operational methods adopted to manage the process to ensure compliance with applicable regulatory and quality requirements, as well as to the Mandatory standards (where available).



for printing, the meager current rules

I rgeneral equirements for the inks from printing applied toi MOCA (3) in direct contact with the food are only hinted at in Alrelated to GMP regulation. Cues on printing inks are also found at directive on regenerated cellulose. Where


direct contact between the printed surfaces of regenerated cellulose films and food is prohibited.


Forecast specifiche are contained only in the regulation on plastics. (5) That Indirectly establishes requirements for printing inks, such as specific migration limits (SMLs). Without, however, subjecting the components of printing inks a a to the positive list Of substances authorized on the basis of appropriate risk analysis. (6)

In other words., as the plastics regulation imposes a migration limit on the article finito, any contribution coming from inks contributes indiscriminately to determine compliance.

A unified and specific discipline

, based on risk analysis, is therefore urgently needed.

Dario Dongo and Luca Foltran


(1) Reg. CE n. 1935/04

(2) Reg. CE. n 2023/06

(3) Materials and Ojects intended for the Contact with Alimenti

(4) Dir.


, article 5

(5) Reg. EU no. 10/2011

(6) The scope of the reg. EU 10/11 is in fact extended to the whole of theand plastics, regardless of whether they are printed or less

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