Industry guideline for the Compliance of Paper & Board ... - cepi

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6 Best practice for treatments applied during converting operations Best practices for converting operations should result from a hazard analysis and a risk assessment. For packaging, the risk assessment shall be extended to the whole packaging system. Inks, varnishes and adhesives used for printing and converting should be selected to ensure the lowest possible levels of migration into food by following the requirements of the Regulation 2023/2006. This process should be facilitated by consultation with the suppliers of those materials and their guidance on the use of low migration and low odour products. Reference should be made where appropriate to the EuPIA Guideline (Ref. 13). The following two specific recommendations are made: - UV cured inks: in view of the history of the use of these products and the photoinitiators that they contain, it is recommended that they are not used in any packaging application. However, it is known that certain manufacturers have begun to produce new and safer photoinitiators and operators could use such products following assurances from those manufacturers over their suitability for food contact in the application envisaged. Inks containing mineral oils: in view of the finding of the migration of mineral oils in food (see Clause 4 Note 6), it is recommended that printing inks containing mineral oils are not used for printing paper and board packaging. CITPA members have entered into a self-commitment, together with CEPI members, to phase out the use of mineral oils. See www.cepi.org/topics/foodcontact/pressrelease/mineraloils See also Annex 2 (Requirements for recovered paper) Section 3 and Figure 2. 12
7 Requirements for use within multi-layers 7.1 General This clause provides the requirements for materials and articles intended for food contact and which are composed of two or more layers of different types of materials (termed multi-material multilayers (MMML)) which are intentionally bound together and where one of the layers is paper. The commonly used materials for such multi-layer constructions in combination with paper and board are various types of plastic film and aluminium foil. In considering multi-material multi-layers in which paper or board is present, two cases need to be distinguished: 1. MMML in which paper or board is present together with one or more non-plastic layer(s) such as aluminium foil, or others, but no plastic layer; 2. MMML in which paper and board is present together with at least one plastic layer, and optionally other layers. A plastic layer laminated or extrusion-coated on to a paper web is considered a plastic film in the context of this clause. It has to be noted that such products are often referred to as “coated paper” within the industry although strictly a distinction should be made between the plastic coated papers covered by this clause and papers coated with minerals such as calcium carbonate which are outside the scope of this clause and are covered by Clause 2 and Annex 1 of this Guideline. Other non-plastic coatings, as well as printing inks, are not plastic layers in the context of this clause. Constructions involving packaging applications, such as “bag-in-box” packaging, where the material layers are not intentionally bound together are not MMML. MMML which correspond to case 1 defined above are required to comply with the Framework Regulation 1935/2004 and the GMP Regulation 2023/2006. There is no specific Community legislation laying down detailed requirements for these MMML. MMML which correspond to case 2 defined above, are also required to comply with the Framework Regulation 1935/2004 and the GMP Regulation 2023/2006, but additionally the plastic layer(s) are required to meet specific requirements imposed by Regulation 10/2011 Note: Regulation 10/2011 does not regulate the non-plastic layers or the finished MMML, other than the limit for vinyl chloride monomer. 13
Page 1: FoodContact Industry Guideline for
Page 4 and 5: TABLE OF CONTENTS Foreword 1 1. Int
Page 6 and 7: This Guideline considers the specif
Page 8 and 9: 1 1.1 Objective Introduction This d
Page 10 and 11: 2.2 Demonstration of Compliance In
Page 12 and 13: 4 CHEMICAL Chemical TESTING Testing
Page 14 and 15: 5 If the packaging to food ratio di
Page 18 and 19: 7.2 Requirements 7.2.1 Requirements
Page 20 and 21: 9 Traceability Guidelines Business
Page 22 and 23: References Annexes Annex 1: List of
Page 24 and 25: Annex 2 REQUIREMENTS FOR RECOVERED
Page 26 and 27: Annex 3 testing methods As a genera
Page 28 and 29: Annex 4 Declaration of Compliance T
Page 30 and 31: In these latter cases paper and boa
Page 32 and 33: Figure 1 Compliance Assessment Sche
Page 34: Figure 3 ELEMENTS OF THE DETERMINAT

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