Are Printing Packages with Ink Safe for Food Packaging?

One of the benefits of working with a company who provides packaging services from concept through distribution is the constant focus on safety throughout the entire process. We understand that not only the packaging materials, but also anything that comes into contact with those materials (such as printing ink), need to be both functional and safe for the product and the consumer.
Therefore, all ink applied on packaging supplied by Flair Flexible Packaging ("Flair") is safe for food packaging and complies with safety guidelines and regulations. In addition, all printed packaging supplied by Flair is NOT considered to be in "Direct Food Contact" as explained by the diagrams and descriptions below:
The following diagrams are taken from FDA requirements and definitions regarding printing ink:

Direct Food Contact refers to a printing ink or coating (shown above as a multi-colored line) that is intended by design to be the surface in intimate contact with a food product. By virtue of this intimate contact, components of the printing ink or coating have the potential to migrate into food and, therefore, must be in compliance with the FDA’s indirect food additive guidelines at 21CFR Parts 170-189.

An example of Indirect Food Contact would be a printing ink or coating applied on the outside of food packaging materials (bags, boxes, etc.). Flair’s award-winning rotogravure printing process works this way, with an inner film separating package contents (food) from any ink. The FDA has no specific guidelines for this scenario. The FDA regulates food additives, not food contact. This type of contact – technically no contact – does not in-and-of-itself require compliance with the FDA’s indirect food additive guidelines (21CFR Parts 170-189). Printing and ink application are only regulated when migration occurs.
Flair printing and ink comply with all regulations
All ink Flair uses meets US, Canadian and Korean safety standards.
In addition, all printed packaging supplied by Flair is NOT considered in "Direct Food Contact" because packaging inks are protected by an inner sealant layer of film or is used only on the outside of packaging and will not be the surface in intimate contact with package contents. Furthermore, all of our printed packaging is tested and fully complies with the FDA regulations regarding food contact raw materials, as well as the Canadian and European standards.
CFIA and HPFB
The Canadian Food Inspection Agency (CFIA) and the Health Products and Food Branch of Health Canada (HPFB) are both responsible for food packaging issues and regulation. Health Canada sets standards and evaluated food packaging against these standards.
According to CFIA and HPFB, if the food package has a functional barrier between the food and the printed ink film or the ink is completely dry and there is no ink set-off 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.
Therefore, Flair also complies with all Canadian regulations for the same reasons explained and illustrated above. Click here to find more information.
Framework Regulation (EC) No 1935/20044
Finally, Flair meets the standards set forth by the European Commission, as explained below,
Framework Regulations (EC) No 1935/20044 related to materials and articles intended to come into contact with foodstuffs provides the basis for the assurance of a high level of protection of human health and of consumers' interests in relation to food packaging, whether printed or not. The manufacturer of the final packaging has the responsibility for the compliance of the material and article with the legal requirements laid down in article 3:
Materials and articles must be manufactured in compliance with good manufacturing practice so that, under their normal or foreseeable conditions of use, they do not transfer their constituents to foodstuffs in quantities which could:
(a) endanger human health;
(b) bring about an unacceptable change in the composition of the food;
(c) bring about a deterioration in the organoleptic characteristics thereof.
There is not yet any specific legislation converning printing inks for food packaging, with the exception of Directive 93/10/EEC relating to materials and articles made of regenerated cellulose film, which states that the printed surface of regenerated cellulose film must not come into contact with food.
The main specific Directive pursuant to the Framework Regulation is Directive 2002/72/EC relating to plastic materials and articles intended to come into contact with foodstuffs. It lays down an overall migration limit (OML) of 60 mg/kg food or 10 mg/dm2 of surface area.
In addition, specific migration limits (SML) or maximum contents in the material or article (QM) are set for individual substances. The Directive contains a positive list of monomers and other starting substances as well as an incomplete list of additives allowed for use in the manufacture of plastic materials (evaluated substances). Substances used only in the manufacture of printing inks are not listed, and thus packaging inks are not under the scope of this Directive. However, if there are ink components which are listed, the relevant restrictions – such as specific migration limits (SML) or maximum content (QM) – have to be met.
The definition of packaging inks also includes primers, lacquers and overprint varnishes applied by flexography, gravure printing or varnishing and roller coating.
References:
This technical bulletin uses information and, at times, direct passages taken from freely available resource materials, such as public guidelines or regulations written by governing organizations or information leaflets produced for public consumption. Some of these references are listed below to provide attribution and allow for more in-depth research:
www.siegwerk.com
Siegwerk Ink Packaging:
"Siegwork Group International Customer Info leaflet - Printing Inks for Food Packaging"
www.canworld.net
INX International Ink Co.:
"Low Migration Inks & Coatings for Packaging Applications"
www.eupia.org
European Printing Ink Association (EuPIA): "Printing Inks for Food Packaging" and "Guideline on Printing Inks applied to the non-food contact surface of food packaging materials and articles"
www.napim.org
National Association of Printing Ink Manufacturers:
"Printing Inks for Food Packaging – FAQ"