Ramu Ramanathan (RR): What is your view about packaging safety?
Jatin Takkar (JT): Siegwerk in India has been on the forefront of packaging safety. The company has proactively banned the use of toluene for solvent-based inks at our Bhiwadi-based manufacturing facility, over two years ago. This was much ahead of the regulatory ban on toluene in India. Furthermore, we have prohibited the use of mineral oil for our offset inks, which are manufactured in the Bhiwadi facility.

RR: What about food items?
JT: When it comes to food items, the basic function of packaging is to keep food fresh and protect it from influences that may deteriorate its quality. The entire value chain of this process involves a delicate balance of chemistry. Thus, if the package is not manufactured, printed and processed properly, it can be a source of chemical contaminants that can migrate into the food. 

RR: This is a matter of concern. 
JT: Oh yes.

RR: What is the challenge and why cannot it be resolved? 
JT: As far as ink is concerned, packaging inks are formulated with different chemicals to meet the packaging demands. These range from resistance against diverse foodstuffs over mechanical and temperature stability, and from deep freeze to retort applications, to facilitate the runnability of the printed material in the industrial packaging machines. These chemicals can have toxic and carcinogenic effects if not properly chosen and carefully formulated as suitable food contact material (FCM) inks.

RR: What is the role of the packaging supply chain in ensuring food safety?
JT: While ink manufacturers are responsible for and can certify the principle suitability of an ink series for food packaging applications, the ink manufacturers cannot warrant the legal compliance of the final printed packaging. 

RR: Why so?
JT: Well, there are other parameters; and these parameters are beyond the control of ink manufacturers.

RR: Such as?
JT: Such as the substrate being used, the printing and converting process, type of food packed, and the storage conditions, among others. 

RR: How can we avoid this?
JT: To avoid problems arising from the use of non-suitable inks, it is important that all parties who are part of the industry start to collaborate. 

RR: What would be the first step?
JT: The first step would be to clearly define the packaging specifications. This is usually the responsibility of the food industry. 

RR: Is it important for packaging supply chain stakeholders to collaborate on transparency in the context of packaging safety?
JT: Undoubtedly. It is absolutely necessary if we are to achieve full compliance and assure customer safety. It is critical to exchange information along the supply chain since it is not about giving the best ink or packaging material, but also about ensuring that it is properly converted and processed during printing. Failure to divulge such facts might lead to difficulties, as has been the case in developed nations like Europe. This has happened during the past decades, and resulted in food safety scandals. As a result, collaboration and information exchange are essential for maintaining food safety standards and avoiding such problems.

RR: How do you see regulations shaping up in the Indian marketplace?
JT: The Food Safety and Standard Authority of India (FSSAI) is taking concrete steps to ensure consumer safety by raising the bar of packaging safety. The FSSAI has enforced Food Safety and Standard (Packaging) Regulations 2018 from 1 July 2019. The standard indicates that a packaging material is to be considered food grade when the material is made of substances which are safe and suitable for their intended use, and shall not endanger human health or result in unacceptable change in the composition of the food or organoleptic characteristics. 

RR: What is the FSSAI mandate?
JT: The FSSAI mandates the brand-owners to use inks for their packaging material which are complying with the IS 15495. 

RR: Any update on the implementation of IS 15495?
JT: The  IS 15495 is a standard created by the Bureau of Indian Standards (BIS) and has been revised. In its current form, IS 15495 reiterates the concept of food grade packaging materials where packaging material shall be manufactured under normal or foreseeable conditions of use. The main idea is: they shall not transfer their constituents to the food in quantities, which may endanger human health. This could cause a deterioration in the organoleptic characteristics or unacceptable change in nature, substance and/or quality of food.

RR: How has BIS tackled this? Any amendments undertaken?
JT: The BIS has made amendments to the standard. The major highlights are: sum of concentration levels of lead, cadmium, mercury and chromium (VI) shall not exceed 100 ppm for printing inks. Also addition of toluene, DBP, DiNP, titanium acetylacetonate to the existing Annex A, which lists the materials and substances that needs to be excluded from the printing ink formulations.

RR: What is the locus standi for toluene?
JT: As per the amendments, toluene will no longer be allowed to be used as a solvent in printing inks which are intended for food applications. This ensures safe packaging for consumers. Phasing out of toluene will not happen in an instant, but it is a step in the right direction. 

RR: How so?
JT: The group that will benefit the most are the workers in printing companies since their occupational exposure to toluene will be reduced. Also, the risk to consumers plus the environment will be minimised.

RR: Are there some more advancements that you foresee in terms of regulatory advancements?
JT: We have embarked on the journey of packaging safety. A lot needs to be done in this space to ensure consumer safety in India. 

RR: Such as?
JT: Mineral oil-based inks, benzophenone-based inks are used in the market. This poses a concern towards consumer safety. While regulators are working to strengthen the standard by excluding many-more chemicals which pose a threat to consumer safety. We would be making a strong development when we move towards a positive list approach. This means, every chemical will be evaluated before being used in the ink formulations.

RR: How do you see the development of packaging safety in the Indian market in terms of its adoption? 
JT: Adoption is not as expected. In my opinion , regulators and responsible associations should create more awareness about the subject. The standard had some significant changes in its latest version.

RR: That's good ...
JT: Yes. But the information needs to reach all the stakeholders of the packaging supply chain. We need to understand that the packaging supply chain is most complex for food safety as it has stakeholders from the food industries but also from the chemical industry (such as ink manufacturers, substrate manufacturers). Therefore an alignment between all the stakeholders is crucial for the success. 

RR: Any good news?
JT: The All India Printing Ink Manufacturers Association (AIPIMA) have released a circular which highlights how ink manufacturers have made the Indian market equipped with IS 15495 toluene-free inks for food packaging applications. Now the FSSAI and brand owners need to ensure the adherence to the IS 15495 toluene-free inks to meet the legal requirements of the country.

 

The link to the AIPIMA notification: https://aipima.org/news-notification/