India, August 2022 – Siegwerk has been the market leader for packaging inks for sensitive applications including Food, Pharma and Hygiene + Cosmetics. The company is committed to their vision of supplying the safest inks worldwide and as a responsible stakeholder of the packaging supply chain, is making all efforts to keep supply chain partners also updated on compliant inks. Making strides towards this vision, the company has recently conducted a session on the topic – “Legal obligations towards Packaging Safety for FMCG Sector and Packaging material suppliers”. The Session was attended by 300 participants and had a detailed Q&A session towards the end. The Session had expert speakers coming from Food Safety and Standard Authority of India (FSSAI), Bureau of Indian Standards (BIS) and Siegwerk, joining together to provide clarity on the legal obligations for FMCG sector and associated packaging suppliers.
Safety aspects of packaging inks is gaining attention worldwide due to the presence of several substances with potential toxicological profiles such as Mineral oils, Toluene, PFA’S, Benzophenone and several others. Globally the discussion around the subject is leading to more awareness in the market which is subsequently pushing the regulators to further raise the bar on packaging safety. The regulations worldwide are getting stricter and harmonized, pushing the supply chain partners to adhere to the new norms. Food Safety and Standards Authority of India (FSSAI) has raised the bar on packaging safety recent food packaging regulations. The Bureau of Indian standards (BIS) has revised the standard IS 15495. Siegwerk being the market leader in India for Food Grade Inks made a sincere attempt to create the awareness in market with support from the Food Safety and Standard Authority of India as well as Bureau of Indian Standards.
Mr. Harish Kumar R.K, Assistant Director, Science and Standard Division (FSSAI) was the first speaker for the session. He highlighted the roles and responsibilities of FSSAI and detailed the process of drafting a regulation at FSSAI. He mentioned that industry has long been focussed on food products, but not on the safety aspects of the packaging/ packaging material and for this reason, there were concerns and this were addressed by FSSAI and for the same reason the FSS (Packaging & Labelling) Regulation, 2011 was split into Packaging Regulation (in effect since 2019), Advertisement & Claim regulation and Labelling & Display regulation to give due importance to Packaging. Mr. Harish mentioned that the FSS(Packaging) regulation was notified on 24th December 2018 and enforced from 1st July 2019 and clarified that the FSSAI regulation is mandatory for the Food Business Operators (FBO’s) and manufacturer of materials to ensure compliance. He then provided details about the regulation an explained how material wise requirements have been specified for Paper & Board, Glass, Metal & Metal alloys, plastics. He further elaborated that in the regulation, definition of Food Grade has been incorporated, Inks have been regulated as per IS 15495 among several other changes. He also mentioned about the recent amendment on use of recycled plastics in food packaging (which is currently only limited to rPET) and the process around the approval of use of recycled plastics. Mr. Harish finally concluded his session with three key messages:
Need of an Integrated approach – Regulatory Information / Knowledge to be shared among the supply chain partners.
Safe Packaging – Contributes to Food Safety and responsibility lies with FBO’s and material manufacturers.
Packaging regulation is a mandatory regulation and needs adherence to ensure compliance.
Mr. Sagar Singh, Deputy Director, Chemical Division (BIS) was the next speaker on the panel. He mentioned that the standard IS 15495, which is now mandated by FSSAI is a standard created by Bureau of Indian standard. He said that although printing inks constitutes a small part of the package, its impact is immensely significant and the next big issue in sustainable packaging is printing inks.
He told the audience that the standards created by BIS are not static but dynamic in nature and recently the standard IS 15495 was revised by incorporating chemicals like Toluene and certain phthalates. He also mentioned that the current ink standard is a negative list standard which restricts certain chemicals in ink formulations.
He further goes on to state that the endeavour of BIS is to adopt for a positive list standard approach where only those chemicals will be prescribed which will be non-hazardous. He elaborated the standard IS 15495, citing the detailed requirements for External packaging, disposables and Immediate food wrappings. He also explained that the standard was first created in 2004 to assist the ink manufacturers to produce inks for food packaging and has been revised providing details about the revision. He further elaborated that there is an ongoing work on the standard which includes NIAS, Inclusion of Mineral oil and Cobalt carboxylates in Annex- A , Xylene and Methylcyclohexane in film printing of food packaging, some photo initiators in Annex- A. He elaborated the concept of NIAS, and concerns associated with it and mentioned that BIS is also working for developing a new standard on Eco-friendly inks. He also mentioned about the several digital initiatives taken by BIS to promote Industry participation, which includes Launch of Standardization Module which gives the provision to provide the comments on standards, provision to become member in standard committee
Next speaker for the session were Mr. Jatin Takkar, Head – Product Safety & Regulatory, Siegwerk India. He broadly spoke about the implementation of packaging safety to ensure consumer safety. He mentioned that ensuring packaging safety is complex as there are different pillar which food and packaging industry had to manage, and this includes regional regulations and Brand Owner requirements, Complex packaging supply chain as well as manufacturer commitments. He mentioned that the regional regulations are different in terms of their structure and associated details and are further supplemented by the brand owner requirements which makes it complex for supply chain to ensure compliance. Apart from this, the regulatory status of the chemicals may change over time, which is yet another challenge which needs to be mitigated by the commitment from the manufacturer itself. And finally, the complex packaging chain with multiple stakeholders, some with expertise on chemicals safety while others with expertise on Food Safety. However, the speaker also mentioned how packaging safety can be ensured by taking different measures across the supply chain which includes:
- Developing understanding of packaging safety and associated legal obligations.
- Developing capabilities for creating specifications and performing risk assessment.
- Promoting transparency and Integration across the supply chain.
- Developing systematic processes and mechanisms around right vendor selection.
- Deploying the monitoring as well as the auding protocols.
He further emphasized upon the correct documentation practices that demonstrates packaging safety. He mentioned that currently a lot of certifications / self-declarations issued by the manufacturers are not adequate enough to demonstrate the compliances however are well accepted by the brand owners because there is limited understanding on packaging safety, associated legal obligations and systematic processes that are required to demonstrate the compliances. He shared examples of the correct certification methodology and explained all clauses that needs to be captured in an authentic declaration. He concluded his session explaining the reasons for creating more awareness on the packaging safety primarily from the brand owners and regulators end as well as need for harmonizing the Indian standards with the best available standards globally.
The session was followed by a detailed Q&A session where all the speakers answered all the questions with the precise answers, again highlighting the need of safe packaging for ensuring consumer safety.