The food contact information maze - a labelling example
European food contact regulations relating to the packaging industry are useful to consider as an example, although it should be noted that there are many other aspects to legislation, such as Registration, Evaluation, Authorisation and Restriction of Chemical Substances (REACH) for chemicals.
Contact with food is a topic that arises frequently in packaging applications, and requests for information increasingly require more technical data to answer in full. As a global materials science and manufacturing company, Avery Dennison designs and manufactures a wide variety of specialised labelling materials and functional materials. Labels are generally placed on the container holding the food product (or any other product), but in some cases they will be placed directly onto the food itself.
Where the label is placed on packaging, what the container is made from will be important. This will determine the extent to which a barrier is formed between the foodstuff and the chemicals in the label (the chemicals contained in the adhesive, facestock and inks). For direct food contact there will be no such barrier, and so we have to ensure that the chemistry used to produce the label is safe to use for its intended purpose. Even the smallest traces of certain chemicals have to be considered in migration models, so working together with all suppliers and suppliers-ofsuppliers is critical in order to find the correct information, and to be able to guarantee the safety of the materials.
Generally a label consists of three layers: a front material (facestock), an adhesive and a release liner. The liner is not applied to the food product itself, and so the focus of food contact regulatory compliance is on the facestocks and adhesives used.
When producing an adhesive, Avery Dennison is bound to requirements laid out in the 1935/2004 Framework Regulation, because there is no specific regulation for this type of material. There are also several guidelines and recommendations available from different industry groups and governments (Feica, FINAT, BfR, etc.) which can be used in order to establish compliance with food contact.
The challenge for a label material or adhesive manufacturer is that the end-use purpose and location is not always known specifically. This means that a material has to receive a general qualification level that fits all purposes and markets. We approximate the most stringent application requirements for our materials by testing according to migration principles from the 10/2011 regulation. Generally, adapted testing is performed to simulate application of an adhesive to a foodstuff directly, which is considered the worst case. These results are then analysed and communicated where needed.
For the facestock, a request is made to the manufacturer for their Compliance Statement. Because of an increasing global supply chain, overcoming the regulatory maze requires the right communication to work towards valid measurements and product information.