Direct vs indirect food contact

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:

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.

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.

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....

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

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.

 

 

Global Guidance for Food Packaging Printing Inks,2015.pdf   2.03MB   80 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.

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:

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 .

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.