Plastics in Food Packaging – A Checklist for
Label Printers
The scope of the EU 10/2011 regulation on plastic materials and articles intended to come into contact with food:  
(a) Materials and articles and parts thereof consisting exclusively of plastics;
(b) Plastic multi-layer materials and articles held together by adhesives or by other means;
(c) Materials and articles referred to in points a) or b) which are printed and/or covered by a coating;
(d) Plastic layers or plastic coatings, forming gaskets in caps and closures that, together with those caps and closures, compose a set of two or more layers of different types of materials;
(e) Plastic layers in multi-material multi-layer materials and articles.
Note that (e) may also relate to labels – ‘multi-material multi-layer’ is a material that contains different materials in several layers, for example paper with film.
Both direct food labels and labels on primary plastic packaging, which are now considered part of the packaging, require Declarations of Conformity (DoCs).   Among other data, DoCs state which authorised but restricted substances are present, and the legislation with which materials are compliant.
FINAT, in a collaborative effort with its member UPM Raflatac EMEA,  reports on the new EU 10/2011 regulation. This regulation on plastic materials and articles intended to come into contact with food came into legal force on January 1. It replaces Commission Directive 2002/72/EC and national legislation based  on that directive. Its purpose is to support brand owners’ and retailers’ duty of care to their customers, and represents an important  additional measure in ongoing endeavours to ensure the quality and safety of food. Label printers who supply to the EU food industry have a key role to play.   

Direct and Indirect Food Contact

The new regulation applies the same principles as EC No 1935/2004 for materials and articles intended to come into contact with food, either directly or indirectly. Such materials are required to be sufficiently inert to inhibit the transfer of substances to food in quantities large enough to endanger human health, and to prevent unwanted changes to the composition of the food and how it looks, tastes or smells. While EC No 1935/2004 applies to food packaging in general, the new EU 10/2011 specifically concerns all components of any primary food packaging containing plastic, with labels considered an integral part of such packaging. Both direct food contact labels furnished with a plastic layer, as well as  all labels applied to plastic primary packaging,  now require Declarations of Conformity (DoCs) stating which controlled but authorised substances are present in their make-up.
Only when the primary packaging material or its final layer provides a functional barrier, such as glass or metal, are labels and other primary packaging components exempt from EU 10/2011. Material compositions that are purely combinations of paper and board continue to be covered by national legislation or recommendations such as those of the German BfR.   

Restricted and Unrestricted Substances

All authorised substances – both restricted and unrestricted -- which may be used in packaging containing plastic in its layers are stipulated on the ‘Union List’ within EU 10/2011, and must be declared at every level of the value chain. Use of restricted substances is permitted only within specific migration limits;  and as DoCs move downstream within the supply/manufacturing chain, such substances must be clearly identified and documented so that compliance can be optimally tested.

Final Responsibility for Conformance Lies with the End User 

It is the end user – packager or brand owner – who has final responsibility for checking that the packaging as a whole conforms to EU 10/2011 (in addition to any extant national legislation for papers, as well as to EC 1935/2004, the Framework regulation for all packaging materials), taking into account  the nature of the packaged food, its defined shelf life, and ambient conditions. Label printers are therefore required to provide DoCs for their labels to enable tests for restricted substance levels and migration behavior in specific environmental conditions to be carried out.   

Label Printers: Responsibilities and Risks

Food label printers supplying into the EU therefore need to be provided with DoCs both from their labelstock and ink suppliers to be able to compile their own DoCs, which must, of course, also incorporate conformance information about any curing processes used during label production.   
It should be noted that the enactment of these regulations means that printers unable to supply DoCs cannot now be accepted as part of the end user’s supply chain, and may also leave themselves open to the financial repercussions of a product recall. It is therefore essential for label printers to be proactive in obtaining and supplying the necessary documentation if they are to retain their place as responsible and viable links in the broader professional packaging chain.  

The Benefits of a Secure Supply Chain

Finally, to summarise, all the above points underline the value of DoCs as a form of insurance for a label printer’s business, as a means of retaining existing customer contracts, and as an entry ticket to end users qualification processes for new business – with the ultimate aim of protecting the consumer. Producing DoCs to a satisfactory standard creates a level playing field for all operations – however large or small.   
(*) This article has been kindly contributed by Jay Betton, Business Segment Manager, Food and Retail Labelling, UPM Raflatac EMEA
Detailed information on EU10/2011 is available on the FINAT website or from Mark Macaré at