UPM addresses food label legal compliance

The firm said that the transitional period is over and it seems most self-adhesive label printers know it from the rise in requests for Declarations of Conformity (DoCs) received by the company during last year’s final quarter.

The Declaration of Conformity (DoCs) is a document signed by the manufacturer to say that the product meets all of the requirements of the applicable directives.

“It’s vital that the new regulation is followed if label printers, brand owners and packers supplying into the EU food industry are to be sure of business continuing as usual​,” said UPM Raflatac.

Replacing directive​

EU 10/2011 replaces Commission Directive 2002/72/EC and legislation based on that directive.

The new regulation applies the same principles as EC No 1935/2004 for materials and articles intended to come into contact directly or indirectly with food.

Such materials 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.

The difference is that while EC No 1935/2004 applies to food packaging generally, EU 10/2011 specifically concerns all components of any primary food packaging containing plastic, with labels considered an integral part of such packaging.

Both direct food labels with a plastic layer and all labels applied to plastic primary packaging now require DoCs stating which controlled but authorized substances are present.

Only when the primary packaging material or its final layer provides a functional barrier, such as glass or metal, are labels and other primary packaging components exempt from EU 10/2011.

Purely paper and board material combinations continue to have only national legislation or recommendations.

Chain of documentation: raw material to packer​

All authorized restricted and unrestricted substances which may be used in packaging containing plastic in its layers are stipulated on the ‘Union List’ within EU 10/2011. Restricted substances are limited according to specific migration limits.

As DoCs move downstream with materials through the manufacturing chain, these substances are documented so that the end-user knows which tests to carry out.

The packer or brand owner has the final responsibility for checking that the packaging as a whole conforms to EU 10/2011 taking into account the nature of the packed food, shelf life and ambient conditions.

DoCs are required from the label printer as a prerequisite to conducting tests for restricted substance levels and migration behaviour in specific environmental conditions. 

Label printers supplying into the EU food industry need DoCs both from their labelstock and ink suppliers, which they attach with or use to compile their own DoCs – also incorporating conformance information about any curing processes.

DoCs – qualification for contracts old and new​

Printers supplying labels into the EU food industry need to be proactive in obtaining and supplying the right documentation if they are to remain a viable link in the packaging and labelling chain. 

Survival in the food industry comes down to more than price competitiveness:  failure to comply with legislation excludes otherwise worthy label printers from brand owners’ and packers’ supply partnerships, and leaves all parties open to the repercussions of potential product recalls.

Having DoCs in good order ensures the continued viability of valuable partnerships, and ultimately works in the interests of consumer safety.

UPM Raflatac supplies DoCs featuring information in regulatory compliance with EU 10/2011; for our faces, adhesives including special food grades and also backings where Multitac (three-layer) label constructions are concerned.