Food industries have been proactive on the risk assessment of the raw materials, however not much has been risk assessed in the case of packaging material. The food safety risk is comparatively higher for the packaging materials since packaging material suppliers and their vendors are not under the control of food authorities, unlike the raw material suppliers and hence have not been linked in the supply chain from the food safety perspective. Brand owners need to collaborate more with their packaging supply chain to assess and mitigate the risks from the packaging material.

Food Safety and Standards Authority of India is revamping their standards on packaging to make it safer for consumers. However, the onus of food safety still lies with the brand owners who are primarily responsible for their products. FSSAI in their recent draft have defined food grade packaging as something that shall not endanger human health, bring any change in composition of food and organoleptic characteristics. 

Ensuring packaging safety is not that easy as there are multiple stakeholders in the packaging supply chain contributing to the development of a packaging material, such as an ink manufacturer, adhesive manufacturers, substrate manufacturers, printers etc. Packaging safety implementation requires all the stakeholders to be aligned to the legal requirements of the region as well as brand owner requirements (if any). Hence, to ensure packaging safety it becomes very important that the stakeholders are transparent in their communications so as to deploy an integrated approach. All the stakeholders in the packaging supply chain needs to proactively share necessary information and documents along the entire packaging supply chain that would enable risk and compliance assessments of the final printed article 

Concept of safe inks
The word “safe inks” and “food grade inks” is a commonly used abbreviation by the brand owners when they intend to ask for inks that will not allow the migration of contaminants which can possibly impact food safety aspects of their product. However, in absence of any standard definition for  food grade inks /safe inks , different misnomers have been introduced and are now prevalent in the market , most common of which are Non-Toluene inks (NT inks) , Non-Toluene Non-ketone Inks (NTNK inks ), mineral oil free inks, cobalt drier free inks etc. However, we need to know whether these inks really safe?

To know about this, we need to understand the concept of safe packaging inks or migration optimised inks. Migration optimised inks are inks which have been formulated with careful selection of raw materials in accordance with legal requirements of the region, brand owner requirements as well as self-commitment from the ink manufacturers. Ink manufacturers not only need to carefully select the raw materials but also keep themselves updated on changing legal and other requirements as well as reclassification of the used raw materials. In addition to that, ink manufacturers also need to validate the migrants for the worst case calculation and shall share transparently the results with the downstream stakeholders for the risk assessment of the packaging material.

Now, we also need to understand how migration optimised inks are safe over than say NT inks, NTNK inks etc. Ink formulations can be categorised into four components – binders, pigments, additives and solvents. Each category is responsible for a specific technical function. An ink at the constituent level can be seen as a mixture of even 60-80 chemicals, categorised into different categories with specific technical functions. However, substitution of a single substance of concern such as toluene, mineral oils, cobalt driers among the gamut of chemicals doesn’t make inks suitable for use for food packaging. Hence, all the chemicals used in formulation of inks need to be risk assessed to make sure that inks intended for the food applications are actually safe and doesn’t detoriate the quality and organoleptic characteristics of the food product.

NTNK Inks- A safety gimmick?
For instance, let us assume you procure NTNK inks from a supplier. In such a case you only have the assurance that the ink doesn’t contain toluene and ketone as the solvents. However, this doesn’t give you any assurance that the ink doesn’t contain other solvents like benzene, monochlorobenzene ( regulated under IS 15495) , heavy metals , formaldehyde ( regulated by few brand owners) ,  CMR (carcinogenic, mutagenic , toxic to reproduction) category chemicals (regulated by self-commitment from ink manufacturer) . In totality, NTNK inks do not give you an assurance that the inks are compliant to legal requirements, applicable to brand owner requirements as well as self-commitments from a responsible ink manufacturer. 

This means use of only NTNK inks can have following results 
•    Possible failure against legal requirements (domestic as well as export)
•    Possible failure against the brand owner requirements
•    Possible failure against the self-commitments from an ink manufacturer and can lead to following consequences:
•    Damaged brand reputation
•    Financial losses
•    Product recall / scandals
•    Media trials
•    Regulatory authority trials 
•    Sales loss
•    And in extreme cases, entire business loss.

Migration optimised inks – the right way ahead
Migration optimised inks are a set of inks where all raw materials have been carefully selected to minimise the potential for the transfer of contaminants from inks into the food. These inks go far beyond the legal requirements and ensure full compliance with the EUPIA guidelines amongst the EUPIA GMP. These packaging inks are formulated and manufactured taking into consideration many individual and varying parameters relating to substrate, application and end use.

The main features of the migration optimised inks:
•    Careful selection of raw materials across the categories – binders, pigments, additives, solvents.
•    Compliant with the EUPIA exclusion policy hence excluding the CMR category material. 
•    Compliant with the legal requirements for the ink manufacturer as prescribed under IS 15495
•    In principle, comply with the definition of “food grade” as specified under Food Safety and Standard (Packaging) regulations, 2018, soon to be notified by FSSAI.
•    Compliant with the high-end brand owner requirements.
•    Compliances validated through systematic process to offer safe inks consistently.
•    Validated risk assessments available in form of statement of composition.
•    Safeguards your domestic and exports business as these solutions are compliant to stringent regulations across the globe.

Having said that, it has to be acknowledged that migration optimised inks need to be supplemented with the good manufacturing practices at the converter shop floor and validation of the final printed article, to ensure safe packaging for food products. Needless to say, getting migration optimized inks from a responsible ink supplier and following an integrated approach across the packaging supply chain is most critical for implementing safe packaging.

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Jatin Takkar is the manager – product safety and regulatory at Siegwerk India. He is a food technologist and has worked with various MNC’s like Nestle and Kraft Heinz before settling in at Siegwerk India. At Siegwerk, Takkar is responsible for the product safety and regulatory segment and ensures the formulation of compliant inks which are demonstrated by systems and supported by documentation. He is also involved in creating awareness on compliant ink systems.