All food packaging materials including self adhesive labels applied to food packages need to comply with the Frame regulation EC 1935/2004. Materials intended to come into contact directly or indirectly with food must be sufficiently inert
- to prevent the transfer of substances to food in quantities large enough to endanger human health, and
- to prevent unacceptable changes to the composition of the food and how it looks, tastes or smells.
Regulation EU 10/2011 addresses all plastic materials and articles that intend to come into contact with food. The regulation applies to any filmic layer of the food packaging also taking into account multi-layer, multi material constructions. Labels intended to food packaging are considered an integral part of such packaging. A filmic face material has to comply fully with the regulation. Adhesive and other coatings need to comply to applicable parts of the regulation. Both direct food labels with a plastic layer and all labels applied to plastic primary packaging now require Declarations of Conformity (DoCs).
Paper materials must comply with the Frame Regulation EC 1935/2004, national legislation in EU member states and relevant BfR recommendations. Currently there is no common legislation for papers at EU level.
Food and Drug Administration (FDA) regulations and BfR recommendations are not legally binding in Europe. However, in the USA, FDA regulations are mandatory.
The GMP regulation for materials and articles intended to come into contact with food (Regulation EC 2023/2006) lays down the rules for good manufacturing practice for groups of materials and articles that are listed in Regulation EC 1935/2004, Annex I, including adhesives, paper and board, plastics, printing inks, silicones and varnishes and coatings. The regulation applies to all sectors and stages of manufacture, processing and distribution of materials and articles intended for food contact. The good manufacturing practice is mainly directed at quality assurance system controls and documentation and it is integrated into our ISO 9001:2008 quality management system.
Declaration of Conformity (DoC) is a formal document manufacturers must provide for plastic materials intended for food contact. A label needs a DoC unless not adhered on a food packaging itself or there is a “functional barrier” between the food and the label preventing possible migration. UPM Raflatac provides comprehensive DoCs for a large range of filmic face materials and adequate compliance information in the format of DoC for adhesives and paper face materials.
In the Declaration of Conformity document we provide “Specification of use” based on the migration tests carried out by a third party accredited laboratory. Label printers are welcome to contact their local UPM Raflatac technical sales or sales offices for assistance obtaining the necessary documentation, advice and support.