On 17 January 2022,Germany has published the 21st Ordinance to amend the Consumer Products Regulation pertaining to the use of printing inks or varnishes on food contact articles and materials.

In addition to the necessary updates for the definitions (Points 7 to 13) of Article 2 of the Regulation, it also defined the use of preparations for coloring food contact materials and decorative colors for food contact materials made of ceramic or glass that are applied in a firing process are not printing inks.

Permitted substances for the manufacture of printed food contact articles and materials:

• Shall be polymers obtained from monomers or other starting substances listed in Table 1 of Appendix 14 (the Positive list), and
• Shall be the substances listed in Table 1 of Appendix 14 as monomers or other starting substances, or as colorants, solvents, photoinitiators or other additives
• The substances may only be used if they comply with the other restrictions, specifications and purity requirements set out in Column 8 of Table 1 of Appendix 14. If no purity requirements are stipulated, the substances must be of good technical quality with regard to the purity requirements.
• Substances in the form of nanomaterials may only be used if this is clearly specified in Column 8 of Table 1 of Appendix 14
• Moreover, monomers or other starting materials and additives may be used in the printing inks for the manufacture of printed food contact materials, if:
• it is on the Union list (Annex I) of the current version of Regulation (EU) No. 10/2011 on plastic articles and materials intended to come into contact with food
• comply with Article 8 General requirement on substances of the current version of Regulation (EU) No. 10/2011
• based on the printed food contact material, comply with the limit values for the transfer to the foodstuff specified in Column 8 of Table 1 of Annex I of Regulation (EU) No. 10/2011 of the currently applicable version
• The pigments listed in Table 2 of Appendix 14, may also be used for the printing of food contact materials and articles which is foreseeable but not intended come into direct contact with food, under the conditions, specifications and purity requirements as stipulated.(Will only applicable until December 31, 2026)

Further, the transitions of barium, iron, cobalt, copper, lithium, manganese, zinc and primary aromatic amines must not exceed the limit values ​​specified in Table 4 of Appendix 14.

Substances listed in Table 1 of Appendix 14, for which no specific migration limit value, no group limit value or no other restrictions are specified in Table 1 or 3 Appendix 14, may only be transferred from printed food contact materials to food up to a maximum quantity of 60 milligrams per kilogram of the food.

For printing inks that are not intended to come into direct contact with the food (Paragraph 7 of Article 4), the transfer of substances, other than those in the form of nanomaterials, to food shall be undetectable. A transfer of up to 0.01 milligrams per kilogram of the food is considered undetectable.

Effective dates:

• All changes shall only apply from January 1, 2026
• Printed food contact materials or articles that were placed on the market on or before December 31, 2025, may still be allowed on the market after this date until sold out.
• Food contact materials and articles which are foreseeable but not intended come into direct contact with food that are printed using pigments listed in Table 2 of Appendix 14 that were placed on the market on or before December 31, 2026, may still be allowed on the market after this date until sold out.

About Intertek

Intertek is a leading Total Quality Assurance provider to industries worldwide. Our network of more than 1,000 laboratories and offices and more than 100 countries, delivers innovative and bespoke Assurance, Testing, Inspection and Certification solutions for our customers’ operations and supply chains. Intertek Total Quality Assurance expertise, delivered consistently with precision, pace and passion, enabling our customers to power ahead safely.

www.intertek.com.cn