A Familiar Hurdle
UV/EB inks seem to do it all, but will they ever become FDA-approved for direct food packaging?
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Missy Smith
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A third approach is to do the extraction studies and then submit a Food Contact Notification (FCN) to the FDA. “In the FCN, the formulator will basically say, ‘We tested this and it looks good to us. Is it OK to use these raw materials in basically this way without further testing?’” says Duncan, who is also co-chair of RadTech International’s Printing & Packaging Focus Group. “If the FDA says ‘yes,’ then that formulator is good to go. Since the approval information is limited to the submitter, every formulator would have to submit its own FCN.” But, he says methods two and three have significant up-front costs for testing, and the third approach has some FDA fees associated with FCN submission.
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