Sun Chemical about Low Migration Inks
Jonathan Sexton, European Product Manager Energy Curing at Sun Chemical provides his thoughts and insight into the key questions surrounding low migration inks.
What actually is the definition of Low Migration?
Despite the widespread use of the term ‘low migration’, there still doesn’t appear to be one definitive industry definition, and as a result, it is often interpreted in different ways by the various stakeholders.
According to a definition presented by EuPIA, the European Printing Ink Association, low migration means ‘below the applicable Specific Migration Limit (SML)’, which in the case of untested materials, generally refers to a level of 10 parts per billion (ppb). Other suppliers, however, may refer to the overall migration limit of 60 mg per kilogram of food, as defined in the Plastics Regulation EU No 10/2011. But does that necessarily mean that a migration level of 59 mg per kilo of food - which is just within the SML - is actually low and safe?
This lack of a clearly defined standard has undoubtedly caused confusion in the market, with ink suppliers all responding in very different ways depending on their interpretation of the terminology. Some ink suppliers – Sun Chemical included - are taking a more proactive approach, taking full responsibility to ensure their products contain genuinely low migration properties. Others on the other hand, may view this lack of clarity as an opportunity to deflect responsibility away from themselves by putting the onus on the user and how they apply the ink, rather than relying on the inherent lack of migration from the ink itself.
It’s also important to note that ‘low migration’ doesn’t just refer to the ink, as other factors also come in to play in potential substance migration. This includes pack and print design; how the ink is applied and dried; ink coverage; the substrates used; as well as storage conditions of both the ink and the final printed products.
At Sun Chemical, we have taken our interpretation of the definition one step further. We aim to ensure every step is taken to develop low migration inks that offer the highest levels of security to ensure the integrity of the packaged product. Our preferred internal definition for Energy Curing products refers to ‘lowest migration’ for individual component migration below 10ppb, while ‘low migration’ defines those below 50ppb where toxicological data is available.
In addition, where individual component migration is higher than those defined levels, but below the Specific Migration Limit, a definition of ‘controlled migration’ can be used. This ensures that our inks are specifically formulated to limit migration to the relevant ppb level through their chemical composition, even where the package itself offers no or limited barrier properties.
Should the industry be doing more to educate consumers of the potential risks from ink migration?
While there is always an argument to ensure all stakeholders, including consumers, are kept informed, migration often involves a greater understanding of the technical issues. Therefore, educating the general public at the right level requires a care and control.
Consumers are far better informed than ever before, and it only takes a quick internet search to gain an insight into potential health risks. However, in general, they tend to be more concerned about higher profile food issues such as provenance, bacterial contamination, packaging waste, as well as nutritional labelling and the high levels of salt, sugar and fat in food products. Awareness is heightened when packaging related contamination makes headline news, when unfortunately, the tendency of the media is to sensationalise the story to grab the headlines, rather than remain factual and focus on the actual risks, which are usually low.
Every stakeholder in the food supply chain has a part to play in sharing information, so that any risks are eliminated before the products even reach the consumer. Our regulations team for example publish a regular newsletter for our customers, highlighting all the latest regulatory issues and developments that might affect their business. Taking such a proactive approach ensures better industry understanding, which leads to greater compliance and ultimately, safer products.
Do you think the EU will introduce legislation to regulate low migration inks in the future?
Food packaging is already regulated in a range of ways. The EU regulation EC No 1935/2004 provides a general framework for food packaging compliance, which clearly states that packaging and their components must not have any detrimental effect on the safety or organoleptic (taste and smell) properties of the food. This, together with the Good Manufacturing Practice (GMP) regulations set clear obligations on the supply chain.
The situation is further complicated by the introduction of national legislation introduced by several European countries. Switzerland for example has introduced the ‘Swiss Ordinance’ (SR 817.023.21) covering materials and articles in contact with food, which includes provisions applying to packaging inks; Germany is looking at similar legislation, while France has also legislated locally for some specific raw material types used in inks over the years.
Global brand owners are also now driving the need for clarity and compliance in food and non-food packaging, and are increasingly adopting local regulations such as the Swiss Ordinance, and introducing their own corporate policy guidelines into their supply chain policies. In recognition of this, EuPIA has also defined a set of guidelines to enable members and the supply chain to ensure they can meet relevant EU regulations and brand owner requirements.
What proportion of the industry is currently using low migration inks?
While volumes of low migration products are growing every year, the majority of packaging that should probably be decorated with low migration ink is still being printed with standard products. This may be due to a number of reasons, such as the use of legacy systems, or the lack of clear regulations or specifications from brand owners, as well as differences in the type of applications.
In a number of cases, the presence of a functional barrier, or migration testing and risk assessment may provide sufficient justification for not using low migration products, but clearly there is significant further progress to be made in this area.
How do you see the future where ink is concerned?
The issue of low migration is constantly evolving, with the likelihood of further categorisation of materials in the future, more toxicological testing on the effects of migration as well as more countries introducing their own compliance legislation. As the situation develops, it has to be the responsibility of packaging food chain suppliers to constantly monitor developments. Until there is one very specific regulation for low migration inks, interpretation of existing legislation and guidelines remains the key. Where health and safety is concerned - especially for inks used to print the packaging of products intended for human consumption - taking a proactive approach, anticipating changes and keeping one step ahead is the way forward to minimise or eliminate potential risks through migration.