The most fundamental change that is to be expected in the next years is the revision of the EU’s legal framework (Regulation (EC) No. 1935/2004) which is at its core almost 50 years old. Whenever the EU Commission presents its plans we see a paradigm shift of the regulatory concepts: Focussing on the final article instead of regulating material classes.
Furthermore, the Commission wants to move away from the current positive list system, which is static and extremely resource intensive to be kept up to date. Moreover, sustainability requirements shall be included in the framework, at the end of last year a study was published that proposes possible measures: https://transition-pathways.europa.eu/agri-food/publications/study-sustainability-context-food-contact-materials-fcm-view-possible
The shift to the final article will put an even stronger emphasis on the flow of information along the supply chain. The current practice in the packaging ink value chain can for sure serve as inspiration: The so-called Packaging Ink Joint Industry Task Force (PIJITF) has published a guidance on what is the adequate information that should flow along the value chain – upstream and downstream. This document summarises the common understanding of the value chain and was also brought to the attention of the Commission. Also, with regards to the positive lists, the PIJITF has already proposed to use a tiered approach, with certain substances being evaluated by the authorities, while others are subject to industry risk assessment, which aligns with the current ideas of the Commission: https://www.eupia.org/key-topics/food-contact-materials/pijitf-packaging-ink-joint-industry-task-force/
With respect to any sustainability requirements and in order to avoid any overlap, overcomplexity and entanglements, EuPIA together with the value chain advocates that the FCM (food contact material) legislation should focus on consumer safety. As always, the devil is in the details, which are yet to be defined as one cannot provide an assessment of the revision at this stage. The Commission is currently discussing its ideas with experts from industry, academia and NGO in workshops in a thorough and systematic process.
However, it seems there is still a long way to go till a legal proposal is adopted by the Commission, which would be passed to Council and European Parliament.
GIO: Extension of transition period
In Germany, the transition period of the so-called ink ordinance (part of the German “Bedarfsgegenständeverordnung”) should originally have ended December 2025. However, the German government decided to extend the transition period by one year (until 31 December 2026) to give the value chain more time to manage the transition. The extension of the transition period provides a chance to get a few additional substances on the positive list. However, since the main deficiencies of the ordinance remain, the list will not be substantially changed in this year. Since the printing ink industry already offers appropriate solutions, the customers in the converting industry should use the time gained to complete the transition to the new requirements as soon as possible.
SIO: End of transition period
The so-called “Swiss Ordinance” (Ordinance on Materials and Articles in contact with Food SR 817.023.21) sets standards for printed food packaging materials in Switzerland since 2017. With the revision from December 2023, the Swiss authorities have implemented some major changes. The revision has been in force since 1st February 2024 and the transition period ended on 31st January 2026. On the one hand, the Part B is completely removed, and non-listed substances may be used, as long as they do not possess CMR-properties (carcinogenic, mutagenic, or toxic for reproduction) and do not migrate with a detection limit of 10 ppb. These provisions are similar to the GIO.
On the other hand, a (staged) declaration of conformity (DoC) has now become mandatory along the value chain. An official FAQ of the Swiss authorities provides more details on these aspects. Furthermore, EuPIA, in collaboration with our Swiss national association, VSLF, have issued a guidance document and a FAQ (Link: www.eupia.org/key-topics/food-contact-materials/eupia-principles/).
Regarding the DoC it is important to understand that it is a staged DoC, which means that different requirements for different parts of the supply chain apply. For the printing ink a good Statement of Composition (SoC) following the EuPIA guidelines can serve more or less as the ink-stage DoC.
EuPIA: New version of the GMP
Apart from these legislative developments, EuPIA is also constantly improving its concepts. Good Manufacturing Practice (GMP) is a central pillar for ensuring the safety of food contact materials. Since 2009, the EuPIA GMP sets standards and assists in controlling food safety hazards in the design and manufacture of inks, varnishes and coatings designed to be printed onto FCMs. Products developed and manufactured in compliance with the GMP are supporting manufacturers of FCM in supplying products compliant with the applicable legislation in Europe for materials and articles intended to come into contact with food.
The GMP is now available in its 5th completely revised version. Two expert groups on chemical and operational management – have completely reworked and updated the guideline. Among other changes, the structure was modified to be in line with the current ISO9001:2015. Furthermore, the geographical scope of the GMP was expanded to recognise that many EuPIA member companies implement GMP globally.
Also references to relevant other EuPIA documents were included, for example, migration guidelines, Photoinitiator Suitability List or the Risk assessment for Non-Intentionally added Substances (NIAS). The new GMP can be found on the EuPIA webpage: https://www.eupia.org/key-topics/food-contact-materials/eupia-principles/
Apart from these developments, there were many additional adaptations in the EU’s regulatory framework, such as the latest amendments of the plastics regulation or the ban of BPA in food contact, which are beyond the scope of this article. With all these changes and the revision of the framework on the horizon, it is clear that Regulatory Compliance of food packaging inks in the EU will remain a very dynamic area.
Source: Printing inks for food packaging – what’s new - European Coatings
