Regulatory Food Packaging
2018 Setoff in Food Packaging Printing

May 2018 Setoff is the migration of substances from the printed side to the unprinted side of another sheet in a stack, roll or stacked container - learn the facts. 2018 Controlling Setoff in Food Packaging Printing

2018 Printing Inks on Food Packaging Guidance Document - March 2018

March 2018 This guide was prepared by the National Association of Printing Ink Manufacturers (NAPIM),for use by manufacturers of inks and coatings used for non-food contact printing applications. It uses established regulations and recognized standards and represents the collective knowledge of NAPIM member companies. 2018 Printing Ink on Food Packaging Guidance Document March 2018

Foreign Supplier Verification - FDA Guidance

Jan 2018 FDA issued enforcement guidance on the FSVP. The FSVP section begins on page 17 of the linked below. FDA Enforcement Policy for Importation of Food Contact Substances Under the FSVP Regulation

Food Safety Alliance for Packaging - Supply Chain Considerations March 2018

March 2018 This 2018 guide was prepared by the Food Safety Alliance for Packaging (FSAP). This guide provides food packaging supply product stewardship considerations. FSAP Food Packaging Product Stewardship Considerations - 2018

NAPIM Comments on California OEHHA Lead (Pb) Limit in Candy Wrappers

July 28, 2017 State of California - Health and Safety Code (HSC) §110552 Petition Requesting Adoption of Regulations Setting a "Naturally Occurring" Lead Level in Candy Containing Chili and Tamarind. This proposal seeks to implement a 0.1 ppm lead (Pb) limit in food packaging/wrappers. The comments are linked below:
NAPIM OEHHA Comments NAPIM OEHHA Comments

Chinese Food Contact Materials Regulations GB 4806.1-2016

October 2017 National Standard of Food Safety: General safety requirements on Food Contact Materials and their products
This standard specifies the basic requirements, limitation requirements, compliance, test methods, traceability and product information of food contact materials and their products. This standard is applicable to various food contact materials and their products. GB 4806.1-2016

2017 German Ink Ordiance Draft

March 15, 2017 the German Federal Ministry of Food and Agriculture (BMEL) announced a new draft version of the 22nd ordinance amending the Consumer Goods Ordinance (“mineral oil ordinance”). In the beginning of March, the ordinance was sent for written consultations to the federal states of Germany and to industry associations. The draft is in German but there is a summary on the link below:
German Ink Ordinance


EU Commission invites Germany to postpone ink ordinance - September 2016

September 2016 - The Commissioner informed Germany that in 2018 the Commission intends to adopt new Union legislation on printed food contact materials, including printing inks and commonly printed materials such and paper and board. The Commissioner has invited Germany to postpone the adoption of its draft legislation EU Commision letter

Food Packaging Market and Regulatory Compliance Impact - September 2016

September 2016 - - In late 2015 NAPIM entered into a partnership with the Print Industries Market and Research Organization (PRIMIR) to produce the 2016 North American Food Packaging Compliance: Impact on the Printing Industry. The study focuses on data and trends for North America (Mexico, Canada and the U.S.) in the primary food packaging segments. It provides a historical overview of recent trends and insights into trends through 2020 for the major food packaging segments. This study includes a focus on pre-packaged food and beverage (i.e., off-the-shelf retail foods). The goal of the study was to focus on ‘critical risks’ and needs in order to provide real value in risk reduction to suppliers, converters and brand owners. Download here

Food Packaging Chemicals/Substances Lists
March 2017 Careful selection of raw materials for inks used on food packaging is a part of the ink formulation process. This page provides commonly used lists of chemical components both suitable and unsuitable for inks used in non-direct food contact applications. This is not a comprehensive listing. Other requirments may apply. Direct communication with the convertor/brand owner is essential to insure that the appropriate ink system is provided. Consult the NAPIM Guidlelines for Inks on Food Packaging [available late December 2016] for additional guidance.
FDA Activity

January 2016 - The Food and Drug Administration (FDA) is amending the food additive regulations to no longer provide for the use of three specific perfluoroalkyl ethyl containing food-contact substances (FCSs) as oil and water repellants for paper and paperboard for use in contact with aqueous and fatty foods because new data are available as to the toxicity of substances structurally similar to these compounds that demonstrate there is no longer a reasonable certainty of no harm from the food-contact use of these FCS

  • Diethanolamine salts of mono- and bis (1H,1H,2H,2H perfluoroalkyl) phosphates where the alkyl group is even-numbered in the range C8-C18 and the salts have a fluorinecontent of 52.4 percent to 54.4 percent as determined on a solids basis
  • Pentanoic acid, 4,4-bis [(gamma-omega-perfluoro-C8-20-alkyl)thio] derivatives,compounds with diethanolamine (CAS Reg. No. 71608-61-2)
  • Perfluoroalkyl substituted phosphate ester acids, ammonium salts formed by the reaction of 2,2-bis[([gamma], [omega]-perfluoro C4-20 alkylthio) methyl]-1,3- propanediol, polyphosphoric acid and ammonium hydroxide
  • Final Rule

Jan 2016 Food Packaging Migration Tests

Chemical migration from plastic containers

Source: http://www.foodpackagingforum.org/news/chemical-migration-from-plastic-containers
Danish consumer council tests plastic lunch boxes and food containers; no chemicals of concern detected; some containers showed considerable overall chemical migration into warm fatty foods In an article published on January 19, 2016 the Danish Consumer Council THINK Chemicals informs about chemical migration tests conducted with five lunch boxes and three food containers made of plastic. Lunch boxes and food containers were tested for certain chemicals of concern (COCs), such as phthalates, bisphenol A (BPA 80-05-7), and heavy metals. None of the COCs of interest were detected. Further, chemical migration from the lunch boxes and food containers into varying food simulants at different temperatures was measured. The three plastic food containers released chemicals into a heated simulant for fatty foods – two of the three containers did so “to a larger extent”, according to the article. Only the total amount of chemical migrate was measured, the individual substances were not identified. The five lunch boxes, tested at lower temperatures, showed limited to no chemical migration into the food simulants. Christel Søgaard Kirkeby, project manager at the Danish Consumer Council THINK Chemicals, recommends storing warm fatty foods in glass containers to minimize chemical migration. Further, regarding the lunch boxes, she notes that the wrapping paper for the contents should be chosen carefully as it could contain COCs such as polyfluorinated chemicals. Kirkeby thus recommends using eco-labeled parchment paper.
Danish Consumer Council THINK Chemicals (January 19, 2016). “Test: Chemicals from plastic food containers migrate into warm fatty foods.”

Chemical Migration from Bottles

Source:http://www.foodpackagingforum.org/news/chemical-migration-from-bottles
Danish consumer council tests drinking bottles made of plastic, metal, and glass; almost no chemicals of concern detected; 1 metal bottle released small amounts of aluminum, 1 plastic bottle showed small overall chemical migration into sour liquids In an article published on January 22, 2016 the Danish Consumer Council THINK Chemicals informs about chemical migration tests conducted with eight drinking bottles. Four plastic drinking bottles, one glass drinking bottle with a plastic lid, and three metal drinking bottles were tested for chemicals of concern (COCs) such as bisphenol A (BPA, CAS 80-05-7), phthalates, and heavy metals. None of these COCs were detected. However, one of the metal bottles released small amounts of aluminum. The release was below the guideline value but exceeded the limit value for tap water. Further, chemical migration from the plastic bottles into drink simulants for sour liquids like lemonade or juice was measured. One plastic bottle released “small amounts of chemical substances.” Only the total amount of chemical migrate was measured, the individual substances were not identified. Christel Søgaard Kirkeby, project manager at the Danish Consumer Council THINK Chemicals, is pleased with the manufacturers “for producing drinking bottles with almost no unwanted chemicals.”
Danish Consumer Council THINK Chemicals (January 22, 2016). “Drinking bottles do well in chemical test.”

NAPIM and EuPIA Guidance Documents