In 2006-08 in Europe, the chemicals benzophenone and ITX (photoinitiators used in inks and coatings to accept the energy from a UV bulb and pass it to the other ink ingredients to cause curing) were found in baby formula and breakfast cereal. This finding prompted well-publicized product recalls in Europe, during which the police supervised the removal of products from store shelves.
As a result, a large Swiss food manufacturer issued a series of documents to suppliers, some of which referenced the Swiss Ordinances, Annex 6, as to what materials should be used in printed products. These documents prompted a wave of reforms wherein many food manufacturers set standards for chemical migration that exceed local law. Throughout Europe, many countries even changed the law to meet customer-inspired low migration targets.
Over the past few years, Germany has been developing similar regulations limiting what materials can be used in printed products. Once it is released at the end of 2013 or 2014, it is expected that EU will adopt the new German regulations. These rules do not target UV inks or any particular chemical but rather are aimed at migration levels of any chemicals from commercially produced packaging. Therefore, the burden of testing migration is on the printer who produces the commercial package.
What is the Impact in the U.S.?
Although U.S. law only requires that a functional barrier separate food from a package’s print surface, recently, some print buyers with strong European connections have begun to require American converters to use only low migration inks and coatings.
What Should I Do?
Currently, we are unaware of any regulatory action in the U.S. regarding the use of UV inks. Even so, if your cartons are sold anywhere in the EU, we recommend that you contact your ink supplier to discuss whether the ingredients in your inks and coatings are listed on the Swiss Ordinance of the FDHA on articles and materials, Annex 6 and in the upcoming German regulations, once they are released.