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The need for low migration packaging...and compliance
From: Greener Package

The definition, science, and compliance requirements for low-migration packaging are evolving to meet the needs of food brands and consumers, says one supplier's regulatory compliance chief.

Low-migration packaging has become an important issue for brands seeking packaging that satisfies the need for food safety as well as environmental health and safety. The term "low migration" refers to packaging whose constituent ingredients—such as printing inks, coatings, and adhesives—exhibit very low odor, off-flavor, and migration levels, so that they won’t have a negative effect on the safety of the product inside the package.

The issue, while affecting pharmaceutical, personal care, and other industries, has “far-reaching implications to anyone in the supply chain of food packaging,” said Greg Pace, Manager, Global Regulatory Compliance and Product Stewardship with packaging supplier Sun Chemical, in a recent presentation. He started with an explanation of the two basic ways migration occurs:

  • Penetration migration from the printed to the imprinted side of a package substrate; and contact migration in which ink transfers itself from the printed side to the unprinted side of material in a stack or roll.
  • Gas stage migration, which includes evaporation and vapor transfer of volatile materials when consumers boil, make, or otherwise heat a package; and condensation migration through steam distillation, also during heating. (See accompanying chart for details.)

“Some of the biggest scares in the industry have happened because of food packaging," Pace told attendees of a seminar at PACK EXPO 2014. He said some cases may not indicate the presence of a toxic chemical so much as an instance of unacceptable levels of a material in a package that could be deemed a risk according to certain standards. What standards? Requirements are “evolving faster than I think that the raw material supply chain can keep up with,” Pace said, noting that suppliers must now be “aware of not only the business we’re in, but also the business upstream and the business downstream.”

Guidance & ordinance

Who decides the “musts” relating to the acceptable chemicals and thresholds for migration? The marketplace and government. Requirements are evolving and cover topics such as the following with regard to food-contact applications of low-migration packaging:

  • Chemicals must not migrate into the food at unacceptable levels
  • Unapproved chemicals must not be used, and
  • Approved chemicals at acceptable levels must not have an unintended effect on the food

In daily business, these factors affect how materials are bought and sold. In promoting certain inks to brand owners for use on the non food-contact side of primary packaging, for instance, Pace's company promoted the inks' compliance with the “required components listed in Annex 6 of the Swiss Ordinance.” This is a law that was driven by global brand owner Nestlé's Corporate Guidance on the topic. Such guidelines listed acceptable ink ingredients that can be used in packaging, set standards and limitations for packaging ingredients, and recommend low-migration inks and migration testing. In turn, this ordinance has had the de facto effect of a regulation across the European Union, even though Switzerland isn't a member state.

In the last 18 months, Pace noted, the U.S. Food and Drug Administration's latest issuances that show its concern on the matter include tightened guidelines for infant formula packaging based on new toxicological studies of infants from birth to six months. Regulators discarded the old model, he said, because they used the same model of exposure for infants and adults, the impact of ingesting chemicals is “accelerated and exacerbated” for infants, since they can derive most or all of their nutrition from commercial baby formulas.

In addition to preventing background on how migration occurs, Pace also reviewed migration testing and technology, regulatory, compliance and manufacturing procedures that should be engaged in Good Manufacturing Practices to avoid introducing materials that are out of compliance and regulatory compliance. Additionally, he added that low-migration packaging should be implemented with both consumer safety and low-carbon footprint in mind to ensure market acceptance.

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