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Frequently Asked Questions on the Legal Status of Printing Inks, Coatings and Varnishes for the Non-food Contact Surface of Food Packaging

This document provides answers to frequently asked questions related to the legal status of food packaging inks. A special focus is on questions relating to demonstrating compliance of printed food packaging with the relevant legal provisions.


EuPIA Guideline on Printing Inks Applied to the Non-Food Contact Surface of Food Packaging Materials and Articles

In the absence of specific EU legislation for food packaging inks, EuPIA developed a Guideline setting out a mechanism for the selection of raw materials for printing inks intended to be applied on the non-food contact surface of food packaging. It is considered that this Guideline satisfies the current requirements of the food packaging chain.

The guideline is currently undergoing review.

Inventory List comprising Packaging Ink Raw Materials Applied to the Non-Food Contact Surface of Food Packaging

In 2007, EuPIA decided to collate and make publicly available a list of all the substances used in the manufacture of food packaging inks, with the aim of implementing a transparent tool for packaging converters and brand owners. From 2007 to 2013 the list served with useful function, intending to be a reference for competent authorities and other stakeholders. Since 2010, the amendment on food packaging inks of the Swiss Consumer Goods Ordinance is in force which contains a positive list of substances which only may be used in the manufacture of food packaging inks marketed in Switzerland. Germany follows suit and is discussing a similar approach. The consequence of having such listing in national legislation means the EuPIA Inventory List had become superseded by the evolution of legislation and was no longer relevant as an independent, updated document. As a result, it was decided at the end of 2013 that the EuPIA Inventory List should be closed as a document, but would be maintained for the purposes of historical reference only. 

EuPIA Suitability List of Photo-Initiators for Compliant Printing Inks and Varnishes


This list identifies photo-initiators suitable for compliant UV printing inks and varnishes for the non-contact surface of food contact materials. The photo-initiators are clustered into groups according to their toxicological profile and migration potential.



Good Manufacturing Practices (GMP) : Printing Inks for Food Contact Materials

The GMP aims to assist in controlling food safety hazards in the design and manufacture of inks, varnishes and coatings designed to be printed onto Food Contact Materials (FCM), 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 this GMP are supporting manufacturers of food contact materials in supplying products compliant to 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.

Customer Information Note Regarding the Use of Sheetfed Offset Printing Inks / Varnishes and Water-Based Coatings for the Manufacture of Food Packaging made from Paper & Board

The note informs about which sheetfed offset inks/varnishes and waterbased coatings are suitable for the manufacture of food packaging made from paper and board. It includes an overview of types of sheetfed offset inks and varnishes available on the market (offered by EuPIA members), with indication of their suitability for the manufacture of food packaging.

Customer Guidance Note for Using Ink Statements of Composition when Considering Compliance of Food Packaging

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.

Explanatory Note for Suppliers of Ink Raw Materials Regarding Regulatory Compliance of Printed Food Packaging

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.

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