Jump to content

  • Quick Navigation
Photo
- - - - -

Direct vs indirect food contact

packaging ink direct indirect

Best Answer ChristinaG, 20 January 2017 - 07:09 PM

Cris, 

 

I'd recommend finding a way to prove that your ink cannot migrate through the film and onto the product, either through internal testing or via a third party testing facility. And of course, have it documented along with a risk assessment. I can't help but think of the recall Nestle had when ITX was discovered to be leaking (migrating) into one of their products through the packaging. You may also be able to get proof of lack of migration through your ink supplier.

 

If you cannot prove that there is no possibility for migration with your current inks, it may be best to switch to inks that are approved for direct food contact.

Go to the full post


  • You cannot start a new topic
  • Please log in to reply
9 replies to this topic

#1 superchris23

superchris23

    Grade - Active

  • IFSQN Active
  • 14 posts
  • 1 thanks
1
Neutral

  • Canada
    Canada

Posted 19 January 2017 - 04:17 PM

Hi,

 

I'm having a bit of a dilemma.

 

Here it goes. We manufacture flexible packaging (printed and non-printed film). Some of it is for direct food contact an some for indirect food contact (secondary packaging). We always surface print on the film (ink does not come in contact with the food).

Do our inks absolutely have to be for direct contact or can they be for indirect contact (because the printing is on the outside of the packaging) even though the packaging itself is considered direct food contact.

 

Hope it makes sense!

 

Thanks!

Cris 

:helpplease:


  • 0

#2 SQFconsultant

SQFconsultant

    SQFBRCconsultant

  • IFSQN Principal
  • 558 posts
  • 86 thanks
29
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:We specialize in helping food companies to develop & implement SQF & BRC programs in the United States and Panama

Posted 19 January 2017 - 05:06 PM

Well, not really, but I think I get the gist of your Question.

Short answer is NO.

Longer - not sure where the miss read came from, however the question that your consultant would asking... can the ingredients used to make up the 'ink' on the non direct side in any way shape or form bleed thru or drift onto the reverse side that is direct contact.


  • 0

Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#3 SQFconsultant

SQFconsultant

    SQFBRCconsultant

  • IFSQN Principal
  • 558 posts
  • 86 thanks
29
Excellent

  • United States
    United States
  • Gender:Male
  • Interests:We specialize in helping food companies to develop & implement SQF & BRC programs in the United States and Panama

Posted 19 January 2017 - 05:18 PM

Then, again if you are printing one side and it goes from one to another than yhe printed side would come into contact with the side that is direct contact, unless it is a bag roller.


  • 0

Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#4 pooled

pooled

    Grade - MIFSQN

  • IFSQN Member
  • 112 posts
  • 51 thanks
5
Neutral

  • Canada
    Canada
  • Gender:Male
  • Location:Ottawa, Ontario
  • Interests:QA,Health & Safety, GFSI, HACCP, Produce, Surfing

Posted 19 January 2017 - 05:19 PM

I would agree that it doesn't need to be direct however if you can prove to a consultant that you have taken the risk into consideration & have some documentation to back up that if the packaging was used improperly it would not contaminate the product etc....


  • 0

#5 ChristinaG

ChristinaG

    Grade - MIFSQN

  • IFSQN Member
  • 126 posts
  • 52 thanks
11
Good

  • United States
    United States
  • Gender:Female
  • Location:Midwest
  • Interests:Art, Video Games, Gardening, Kayaking, Costuming, Public Health, Writing

Posted 20 January 2017 - 07:09 PM   Best Answer

Cris, 

 

I'd recommend finding a way to prove that your ink cannot migrate through the film and onto the product, either through internal testing or via a third party testing facility. And of course, have it documented along with a risk assessment. I can't help but think of the recall Nestle had when ITX was discovered to be leaking (migrating) into one of their products through the packaging. You may also be able to get proof of lack of migration through your ink supplier.

 

If you cannot prove that there is no possibility for migration with your current inks, it may be best to switch to inks that are approved for direct food contact.


  • 0

-Christina

 

"Imagination is more important than knowledge. For knowledge is limited, whereas imagination embraces the entire world, stimulating progress, giving birth to evolution."- Albert Einstein 


Thanked by 1 Member:

#6 redfox

redfox

    Grade - SIFSQN

  • IFSQN Senior
  • 254 posts
  • 76 thanks
7
Neutral

  • Philippines
    Philippines

Posted 22 January 2017 - 01:03 AM

Hello Superchris23,

 

Send the packed product for migration testing. Plastic material is permeable and the leaching of ink to product is not impossible. Based on the result make a risk assessment of the identified hazard and how you can mitigate the risk. 

 

regards,

redfox


  • 0

#7 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 12,449 posts
  • 3244 thanks
347
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 22 January 2017 - 08:47 AM

Hi Cris,

 

The Canadian Regulatory situation appears to be something like this –
 

 

The Canadian Food Inspection Agency (CFIA) and the Health Products and Food Branch (HPFB) of Health Canada are both responsible for food packaging issues. Health Canada sets standards and evaluates food packaging against these standards. Packaging requirements at federally regulated packaging facilities are enforced by the CFIA. As a best practice, Health Canada recommends that food­packaging companies obtain a Letter of No Objection from the Health Protection Branch for any packaging that may come into contact with food. (It is important to note that a Letter  of No Objection does not absolve the packer from liability, should there be a failure in package design leading to the contamination of the food product.)

 

To obtain a Letter of No Objection, detailed information about the printing and packaging processes is required, along with representative extraction test data, where possible. If the food package has a functional barrier between the food and the printed ink film or, if the ink is completely dry and there is no ink set­off during stacking/nesting of the packages, then the package is considered to have ‘no direct food contact’ with the ink film and a Letter of No Objection is not required.

 

More information can be found in the Canadian Food Inspection Agencies Guidelines for Submissions, Reference Listing of Accepted Construction Materials, Packaging Materials and Non­Food Chemical Products.

 

 

Attached File  Global Guidance for Food Packaging Printing Inks,2015.pdf   2.03MB   24 downloads

 

PS - Note that in the US, the conclusion/answer to the OP is particularly interpreted in respect to food additive considerations, eg via migration data. Some further digging is required to determine whether Canada utilises similar notions / quantitative limits.


  • 0

Kind Regards,

 

Charles.C


Thanked by 2 Members:

#8 superchris23

superchris23

    Grade - Active

  • IFSQN Active
  • 14 posts
  • 1 thanks
1
Neutral

  • Canada
    Canada

Posted 24 January 2017 - 02:53 PM

Thanks to everyone for your input.

 

I will take the migration risk into consideration and also have a friendly chat with our ink supplier. 

 

Merci beaucoup!

:sleazy:


  • 0

#9 dschattner

dschattner

    Grade - Active

  • IFSQN Active
  • 2 posts
  • 0 thanks
1
Neutral

  • Argentina
    Argentina

Posted 26 January 2017 - 01:59 PM

I agree with the migration issue. I think it´s more important and complex than everybody believes. Migration may depend not only on the ink composition , but on the flexible material to be printed and the kind and composition of the food to be packed. According to my experience this is one of the most critical issues regarding practical quality and safety of packaged food .


  • 0

#10 CMHeywood

CMHeywood

    Grade - SIFSQN

  • IFSQN Senior
  • 318 posts
  • 78 thanks
15
Good

  • United States
    United States
  • Gender:Male
  • Location:Neenah, Wisconsin

Posted 31 January 2017 - 05:24 PM

Most inks used on flexible packaging are not approved for direct food contact.  The FDA does not regulate printing inks.

 

You must have a functional barrier.  Can you have someone do a one-sided extraction test to show that nothing at a harmful level is migrating through the packaging?

 

If you surface print, you don't want the printed side to be exposed during the extraction.

 

For the extraction test, you will need to know the food type and the condition of use (packing and storing) that your customers use.

 

Alternative is to see if your ink supplier will make a recommendation on what constitutes a functional barrier, for example, 1 mil PE or thicker.


  • 0





0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users