Data Points: Food Packaging Compliance: Impact on the Printing Industry

In 2005, Nestlé put the company’s Food Packaging Safety Program in place after a massive recall caused by the discovery of traces of isopropyl thioxanthone (a photoinitiator found in printing inks) that was seeping through cartons into the company’s ready-to-drink baby formula. This incident remains one of the central forces in shaping and impacting standards and regulatory compliance in the food packaging industry today. While the Nestlé recall was confined to Europe, North American retailers, brand owners and packaging buyers have begun to take a closer look at their own safety standards for food packaging to establish protocols should a similar event happen in the U.S. or Canada. For brand owners, the lasting consequences of product recalls are serious in terms of both brand loyalty and overall financial impact.

The U.S. food packaging industry will grow at an average rate of 3% annually over the next five years (Exhibit 1). Consumer trends and behavioral shifts continue to push packaging innovations through the supply chain. These trends include more environmentally friendly, recyclable packaging, increased packaging functionality and increased usage of single-serve products for on-the-go lifestyles. In growth rates per food category, the U.S. trails behind global market performance. While North America is the largest regional consumer across all food segments, the industry’s growth (which includes food packaging) is outpaced by emerging markets including China, India and Brazil.

Exhibit 1

At the helm of the packaging supply chain, brand owners and packaging buyers are the intermediary between the compliance regulations passed down from the FDA and the sourcing and procurement of printed products from converters. According to brand owners, when they receive notification from the FDA or USDA that certain chemicals and compounds are no longer allowed in food packaging, or that allowable levels of certain substances have decreased according to condition of use, this information is immediately passed on to printed packaging vendors, asking if the products they are supplying either carry the compounds listed or exceed allowable levels. Brand owners are purposely creating a simple “yes-or-no” letter-writing dynamic with their printed packaging vendors in an effort to shift potential liability should a food crisis occur. However, flexible packaging printers have put their own more rigorous protocols in place to ensure the low migration inks and coatings their customers require fall within regulatory guidelines. These protocols include periodic extraction testing and spot checks in addition to sending their printed applications out to certified independent laboratories. The results are then sent back to their brand owner customers.

Currently, flexible packaging converters are the most knowledgeable about low migration inks and coatings as well as the regulatory and compliance standards that drive their use. Folding carton and label converters are taking measures to establish food packaging compliance protocols, even though they are not currently receiving pressure from their customers to do so. These converters are working with audit and certification companies and establishing tailored, customized programs that specifically address the printing and converting of folding cartons and labels for the food packaging industry.

When it comes to resources for learning about food safety in printed packaging materials, the majority of brand owners turn to their printed packaging vendors (Exhibit 2). Brand owners’ confidence in their printed packaging suppliers’ knowledge when it comes to food safety is primarily driven by flexible packaging companies. These companies are more active in the utilization of low migration inks and coatings and are more knowledgeable than their folding carton and label converting counterparts.

Exhibit 2

While the North American marketplace hasn’t witnessed something on the scale of the Nestlé crisis, industry suppliers and printed packaging converters agree that a crisis of similar scale occurring in the U.S. is inevitable. Also, consumer behavior is erratic. While conditions of use dominate compliance and regulatory processes, consumer behavioral extremes are a moving target. For the brand owner, the ability to predict all outcomes isn’t possible. A North American food packaging crisis is not a matter of “if” but “when.” Regulations will change. These changes will impose significant new responsibilities for food manufacturers and retailers up and down the supply chain. As food safety regulations and compliance standards increase, vendor areas must work more closely together.