EuPIA principles
EuPIA member companies have for many years shown strong commitments related to the manufacture and supply of printing inks for food contact materials (FCM).
Operating on the basis of these commitments has been and still is highly important, especially since there is not yet any specific European Union legislation concerning FCM inks. The EU Framework Regulation (EC) No 1935/2004 is the legal basis for FCM inks regarding printed FCM.
EuPIA assists its members to meet their commitments by issuing a number of guidance documents, which members are encouraged to implement to ensure legal compliance and to safeguard consumer safety when formulating, manufacturing and marketing printing inks for FCM .
Principle of placing consumer safety first
EuPIA has for many years put special emphasis on FCM and consumer safety.
In order to demonstrate to external audiences that they are committed to the principles of protecting food consumer safety within the areas under their control, EuPIA member companies have been offered the opportunity to sign Compliance commitments related to the manufacture and supply of FCM inks.
Principle of transparency and information sharing
Transparency and information sharing along the supply chain is key. To that end, EuPIA has developed a model document called “Statement of Composition (SoC)” meant to give detailed information on potential migrants present in an FCM ink. This document should be available to each FCM ink supplied to converters to enable them to assume their part of the compliance, work whilst concluding on the migration risk from their ready-made packaging. In the case of an SoC intended to cover a group of products, it must include all migrants coming from the individual formulations in the group.
To safeguard legal compliance as well as consumer safety, it is paramount to have detailed knowledge about the identity of raw materials often coming as mixtures and, in the majority of cases, carrying impurities from the production process, many of them being categorized as Non-Intentionally Added Substances (NIAS). In order to get thorough and detailed information on the composition of each raw material used in FCM inks, EuPIA internal guidance for its members is in the form of a “regulatory questionnaire for FCM printing ink raw materials”
This guidance note concerns packaging inks, which are applied on the non-food contact surface of food packaging. It is intended to help printing converters and end users assess the compliance of printed packaging using the information provided by the ink supplier.
This note is intended to assist suppliers of ink raw materials in understanding the need for and the mechanism for regulatory disclosure to facilitate the communication of relevant information down the supply chain.
Principle of implementing Good Manufacturing Practices
The EuPIA Good Manufacturing Practices (GMP) assist in controlling food safety hazards in the design and manufacture of inks, varnishes and coatings designed to be printed onto FCM inks and formulated for use on either the non-food contact or the food contact surfaces of food packaging and articles intended to come into contact with food. Products developed and manufactured in compliance with these GMP are supporting manufacturers of FCM in supplying products compliant with the applicable legislation in Europe for materials and articles intended to come into contact with food, such as the Framework Regulation (EC) No 1935/2004 and GMP Regulation (EC) No 2023/2006.
