There are rising concerns about the possible health risks arising from chemicals migrating into foods from packaging. How do adhesives play a role in migration and how severe can the impact be?
Within the context of food packaging and consumer health, the topic of migration has been of great interest. On a general note, migration is the transfer of substances from the packaging into the food and vice versa. All packaging materials such as paperboard, printing ink or adhesive, and the storage surrounding the packed food, can contribute to migration. This interaction may cause contamination that can lead to a quality loss of the packed food, and it can make the foodstuff unsafe. To avoid such a scenario, migration should be reduced to a minimum level possible.

The polyurethane-based adhesives, widely used in manufacturing flexible laminates, use Polyols and Isocyanates as major ingredients. To make sure that the adhesive is safe, every manufacturer is expected to do a thorough risk assessment in the selection of raw materials, to minimise the migration risks. The risk is subjected to the amount of material that has migrated into the food, and if this material is hazardous or toxic in nature.

How is migration from adhesives different to that of plastic films?
Migration of any kind is the same. It is harmful and can lead to long-term health issues, irrespective of the source from which it originates. In the case of plastic films (for example – polyethylene films), manufacturers need to add additives, such as anti-static, anti-blocking agent, slip additives, etc., to achieve the characteristics demanded by and for the end application. It is imperative to choose the correct raw materials and processes, both in films and adhesives manufacturing, to be food safe and to be able to prove food safety with clear certifications when demanded. 

In India, where do food manufacturing companies stand in terms of their understanding of food safety and selection of appropriate packaging materials concerning this?
The understanding about food safety has been on a rise over the past decade. Formation of FSSAI (Food Safety and Standards Authority of India), a regulatory body, and ascertaining standards for the industry is the first step in the direction of attaining 100% food safety compliance both during and post-production processes associated with food manufacturing. The companies in India depending upon their size and scale follow a different set of guidelines and standards. While global players follow stringent norms, their counterparts in India often choose to ignore the guidelines since there are no clear provisions for laminates manufacturing process mandated yet by local government bodies for food safe packaging. This is expected to change with the involvement of regulatory bodies such as BIS (Bureau of Indian Standards) and FSSAI.

In India, where do packaging converters stand in terms of their understanding of food safety and selection of appropriate packaging materials concerning this?
The Indian flexible packaging industry has more than 1000 players. The understanding on the topic of food safety is very clear and sound among the top of the pyramid converters, who are a handful in terms of numbers. However, it is noteworthy that these converters cater to a large portion of the market in terms of capacities built. They do take necessary precautions in ensuring their choices do not put themselves and their customers in trouble. The next rung is a mixed bag. Some of the aspirational ones are partly aware of food safety and its importance. These entities provide a food safe option only to those customers who demand it. So clearly, the focus is on demand-driven food safety. This set of converters form close to 30-40% in numbers and cater to 30% of the overall market. Most of the small players are neither aware of the importance of food-safe packaging nor are interested in knowing more on the subject.

How different are food safe adhesives from the regular ones?
In the flexible packaging industry, use of approved raw materials (also not using banned substances) and adherence to set protocols and SOPs laid out by the universally accepted food packaging guidelines such as those of EC / EU / FDA for adhesives manufacturing form the basic steps to ascertain food safety. Polyurethane-based adhesives are supplied in two components (OH, NCO). In the process of deriving polyurethane polymer post mixture, moisture continuously reacts with residual NCO to form Primary Aromatic Amine (PAA). If PAA migrates into the packed food, it is detrimental to human health upon consumption. Sufficient curing time should be provided, as per manufacturer’s instructions in the Technical Data Sheet (TDS), to ensure food safety of the adhesive used. Flexible laminate manufacturers, in high demand situations, do not get sufficient time for curing the rolls. This leads to improper amine decay. This potentially has the risk of migrating into the food, if such rolls are slit and used immediately to pack foods. Food safe adhesives are those which not only follow the basic steps, but also support fast curing to ensure 100% compliance in food packaging.

We heard about upcoming Indian regulations on packaging safety. Can you brief us on what does it entail and how this will make consumer health safer?
The standards will be set forth basis science-based facts with an advanced monitoring system to tackle exceptions and violations. The focus will still be on consumers and their rights to safe food for consumption. The regulations will necessitate stakeholders in the food value chain to be more accountable, ensuring the delivery of safe products to customers.

What does it entail from an adhesive point of view?
Choosing the right adhesives and coatings is crucial for converters to produce food-safe laminates and to achieve the desired packaging performance with regards filling good resistance, retort, convenience, barrier properties, seal-ability or mechanical protection of foodstuff. Converters will need to eliminate potential risks for food safety during the manufacturing process, including mix-ratio and online coating weight management, testing of laminates (for migration, incorrect adhesive application or solvent retention). The aforesaid risks can have multiple causes and can impact the safety of the final food product packed, which may expose consumers to health risks. It is therefore crucial that these factors are continuously monitored, suitably addressed to minimise risks.

How prepared, according to you, is the packaging supply chain in India to comply with the regulation?
The packaging supply chain majorly involves converters and raw material suppliers, namely ink, adhesive, polyester or film. Currently, there are very few suppliers who can produce food safety compliant products. This applies to all supply categories, since there is no clear mandate or guideline. When there will be a strong push from regulatory bodies, this trend is bound to change. At the moment, the industry is stepping up towards food safety compliance with reluctance, as it is considered as an additional cost and the choice to choose food safe raw materials still lies with the converters.

Are you engaged in a dialogue with the FSSAI officials? What are your inputs and concerns?
We are working on liaising with the FSSAI officials. Given an opportunity, we would like to discuss on the critical needs of the industry and how we can contribute as a global organization that has made substantial contributions to the leading food safety regulators such as that of the EU.

Have you proactively made initiatives before to help brand and packaging converters deliver safe packages for your customers?
Henkel believes in working with its customers to find a solution to the challenges faced by them. The industry lacked a professional training academy for flexible packaging. Thus, in 2016, we invested in a dedicated Flexible Packaging Academy, in Mumbai, which runs a curriculum (co-curated by the Indian Institute of Packaging, as a knowledge partner) of five days theory and practical sessions. Seasoned trainers from across the world come to the Academy to offer their expertise to the candidates, who are mostly operators of large manufacturers or the proprietors of smaller firms. In a small way, we have been bringing about an awareness on food safety through this medium. Besides this, we also participate in industry thought-leadership workshops to communicate the message on food safety to the best of our ability.

How do you see packaging evolving in terms of compliances in the next five years?
Today, initiatives are undertaken by regulatory authorities such as FSSAI, BIS; industry bodies such as CII, FICCI, ASSOCHAM, which are further fuelled by brands setting stringent standards for quality and food safety. We strongly feel this trend is here to stay and shall become more prominent in the future to attain compliances. The end consumers who were invisible in the packaged food value chain, are clearly coming out in communicating their needs and aspirations, demanding their rights to safe food for consumption. The next decade is of consumers, who are digitally well connected and well informed. This is expected to drive the industry towards food safety compliance sooner than later.

What are the food safety standards across the globe and how different are they from what FSSAI is proposing?
There are two widely accepted, prominent global regulations and standards, namely the EU Framework Regulation and FDA. Countries where there are no prevailing regulations for food safety, by natural choice adhere to either of the two cited standards, which are known to be complete and thorough in protecting the interest of consumers. The FSSAI has included many provisions from the standards of both FDA and EFSA that are relevant to India. There is more work being carried out by the expert panels to improvise the standards laid down in 2010 for the industry. The experts are deep diving into various aspects including but not limiting to packed foods. They are emphasising stringent food safety guidelines for not just the food business owners but also all the players in the food value chain, including packaged food manufacturers and all their direct and indirect suppliers.