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Cross contamination of non-compliant inks can be minimised by keeping same ink type per job, dedicated
machine room, and or printing press, excellent in-house; ink room management processes, excellent job
change procedures, printed reel and transport / storage conditions. Converters need full transparency on
possible migrants for management of food safety. The company supports the converters in providing qualified
information on migrants through SoC (statement of compositions). In Indian market, “Toluene Free (TF)” or
“Non-Toluene Non-Ketone (NTNK)” inks are considered to be safe. However, this is not always true. Even
other substances which are part of the supplied raw material such as process aids and additives may contain
potential migrants and end up as part of the ink system which can migrate into the food and in turn makes it
unacceptable for human consumption.
Food Packaging
The ‘Food Safety and Standards Act’ (FSSA, No. 34 of 2006) introduces regulation on food contaminants, in
particular including contaminants from packaging. Specific provisions on packaging are detailed out in the
‘Food Safety and Standards (Packaging and Labelling) Regulations, 2011. Section 2.1.1 (2) regulates plastics
in contact with food, stating generally that “containers made of plastic materials should conform to the
following Indian Standard Specification (IS)” (followed by a list of 10 Indian Standards on 10 different plastic
types previously issued by the Bureau of Indian Standards). These standards include overall migration limits
(identical to those in the EU) and/or positive lists of authorised substances for the 10 plastic types (but not
for printed layers), with maximum concentration limits.
Ink
The voluntary Indian Standard IS 15495:2004 ‘Printing ink for food packaging – Code of practice’ prescribes
guidelines for printing inks for use on food packages. The standard differentiates among four categories of
printing inks:
The exclusion list in Annex A comprises pigments and compounds based on antimony, arsenic, cadmium,
chromium (IV), lead, mercury and selenium as well as several dye colorants, solvents, plasticisers and other
compounds (e.g. dioxines, nitrosamines and others).
It is less demanding than the JPIMA and EuPIA exclusion lists – in particular, toxic phthalate ester plasticisers
usable in solvent-based inks are not banned, the aromatic hydrocarbon-based solvent “Toluene” is not
restricted.
Types of migration
1) Set-off migration
Migrants can migrate from one layer to another, such as a surface printed layer to the non-printed food-
contact surface which is later on brought into contact with food. If these are in direct or close contact like in a
reel or a stack after printing, set-off migration can occur due to the pressure existing in the reel or stack.
2) Diffusion migration
Small and mobile molecules can easily penetrate into and diffuse across packaging material layers. This can
occur even if the printed material has not yet been converted into a food package and filled with food, or later
on when the printed package is filled with food and the food starts to ‘extract’ the migrants from the
packaging material.
3) Gas-phase migration
Migrants can also migrate from a cardboard (the ‘releasing reservoir’) via the gas phase within the pack, to
end up in food which acts as ‘recipient reservoir’ (gas phase migration). This can, for example, occur with
migrants such as mineral oils or some UV photoinitiators that might not be generally known as being volatile
such as organic solvents.
When doing migration testing, it is critical to consider the complete packaging value chain. The right choice of
ink and related materials such as adhesives, barrier properties of substrates. Design of packaging, conversion
of the substrates, packaging and storage conditions must be integral for controlling migration.
It is critical to be aware of migration principles and related regulations. The more we know and apply food
safety concepts towards packaging, the better we can provide our consumers a “peace of mind.” We, at
Siegwerk, are always ready for support and are prepared to be challenged on our part of responsibility along
the packaging chain.
(The author is head,(flexible packaging), technology development, Siegwerk India Pvt. Ltd)