Demystifying food contact material regulations for label & narrow web printing

In food packaging, ensuring safety is paramount. This responsibility means that the inks and coatings that can be used on food contact materials (FCMs) are strictly regulated to ensure they do not pose health risks or affect food properties.

For label and narrow web printers, navigating this complex landscape might seem daunting. However, understanding it is essential – not just for compliance, but for building trust with brand owners too.

Fragmented and evolving FCM regulations

One major challenge with FCM regulations is their lack of universality. There is no single global standard for printing inks and coatings used in food packaging – instead, printers must comply with a patchwork network of national and regional rules.

To add to this complexity, these regulations are constantly evolving, reflecting advancements in scientific understanding and consumer safety concerns. This changing landscape makes it critical for stakeholders – including brand owners – to stay informed about current and upcoming requirements.

EU Framework Regulation (EC) No. 1935/2004

At the heart of European FCM legislation lies the EU Framework Regulation (EC) No. 1935/2004. This regulation establishes general safety requirements for all materials intended to come into contact with food. It mandates that such materials must not:

• Endanger human health
• Alter the composition of food
• Deteriorate its taste or odour

Although this framework forms a solid foundation, it does not include specific rules for printing inks, leaving individual member states to develop their measures. Instead, compliance relies on Good Manufacturing Practices (GMP) as outlined in Regulation (EC) No. 2023/2006, which includes requirements on product composition, quality, and hygiene management. Printers must work closely with ink manufacturers to ensure their products meet these standards.

The Swiss Ordinance

The Swiss Ordinance on Materials and Articles in Contact with Food has long served as a benchmark for FCM printing across the industry. This ordinance included a positive list of substances authorised for use in printing inks, divided into two categories:

• Part A: Fully evaluated substances with toxicological data that have been assigned a specific migration limit.
• Part B: Substances allowed under strict migration limits (below 10ppb) if they are non-carcinogenic, non-mutagenic, and non-toxic to reproduction.

Only substances listed in the ordinance’s Annex 10 can be used in printing inks applied to food packaging, and migration limits must not be exceeded.

Recent updates to the Swiss Ordinance have further tightened these requirements. Part B and non-evaluated substances have been phased out, meaning only fully evaluated substances will be permitted in future formulations, from early 2026 onwards.

Although this Ordinance only applies in Switzerland, the patchwork nature of most FCM rules and regulations mean many companies operating in other countries have adopted it as a reference point. As a result, Swiss Ordinance rules are commonly used for FCM printing across the label and narrow web sector.

The German Printing Inks Ordinance: a new standard?

Germany is set to soon introduce its own FCM rules in the form of the German Printing Inks Ordinance (GIO). Scheduled to become mandatory by January 2026, this regulation establishes its own positive list of authorised substances for printing inks and varnishes used in FCMs. It also sets specific migration limits to prevent harmful substances from transferring into food.

Unlike the Swiss Ordinance, the GIO applies to both direct and indirect food contact inks but exempts cases where functional barriers prevent migration. However, this new ordinance has the potential to be adopted as a new benchmark for the industry. Printers will need to work closely with ink manufacturers to ensure compliance through documentation like Statements of Composition and thorough migration testing.

Why brand owners must care about FCM compliance

Brand owners play a crucial role in ensuring FCM compliance across the supply chain. By requiring converters to use FCM-approved inks, they can safeguard consumer health while protecting their brand reputation. Non-compliance can lead to costly recalls, legal penalties, and loss of consumer trust.

Educating brand owners about these regulations is vital as some may be unaware that responsibility for compliance often extends beyond ink manufacturers to include printers and converters.

Staying ahead in a complex landscape

Given the fragmented regulatory landscape, collaboration between all stakeholders – ink manufacturers, printers, converters, and brand owners – is essential to staying ahead. Printers should work with trusted ink suppliers that adhere to GMP and provide detailed documentation on ink composition and migration potential.

Additionally, proactive communication with brand owners can help them understand their responsibilities under different regulations. By highlighting the importance of using compliant inks, printers can position themselves as valuable partners in ensuring food safety.

Flint Group recognises the challenges posed by this regulatory complexity. The company’s expertise in narrow web inks and coatings equips it to support printers in navigating these rules while maintaining high production standards – but that’s not all. Flint Group is proud to offer Flexocure® LEAP, the market’s first ink range developed using new curing technology that significantly reduces the risk of migration.

Based on a revolutionary resin system, Flexocure® LEAP is designed to safeguard food packaging with innovation that minimises migration and maximising consumer trust. The next-generation UV Hg curing system significantly reduces the mobility of ink ingredients and minimises the risk of migration to ensure compliance with stringent regulatory standards.

This advanced containment approach not only protects the integrity of printed packaging but also enhances brand reputation by putting safety first. What’s more, with fewer commonly tested constituents, the range benefits from reduced migration testing requirements, offering greater efficiency and cost effectiveness for brand owners and converters alike – all without any compromise on performance.

By staying informed and proactive, printers can turn compliance into an opportunity. Products like Flexocure® LEAP, supported by Flint Group’s expertise, make it easier to build trust with customers through safe, high-quality packaging that makes compliance a breeze. This ground-breaking technology delivers more than just a cure – it ensures confidence in every print.

To find out more about Flexocure® LEAP or learn more about how Flint Group can support your business with FCM regulation compliance, contact your local Flint Group Label & Narrow Web sales representative.