What it is
"Suitable for food contact" is not a quality of a material in the abstract: it is a judgement on a material, in a precise use, with a precise food. The European framework starts from Regulation 1935/2004, which sets the general principle — a material intended for contact must not transfer substances to the food in quantities capable of endangering health or of altering its taste, odour and composition — and from Regulation 2023/2006 on good manufacturing practice. For plastics there is a specific measure, Regulation 10/2011, with positive lists and migration limits. For paper and board there is no harmonised European measure: the work is done with national rules and with the technical references the market has adopted in practice. That is why the question "is it suitable?" has no blunt answer without knowing what is going inside.
Inks follow the same logic. They are not in contact with the food, they are on the outside, but substances can reach the other side by three routes: through the substrate, from one sheet to the next in the pile or in the reel — set-off — or by evaporating and recondensing inside the pack. This is why low-migration series exist: they are formulated to reduce mobile substances, photoinitiators, residual monomers and oligomers, and they have to be used with dedicated printing procedures. And this is why a low-migration ink does not make a pack compliant on its own: what also counts is the food (fatty, aqueous, dry), the contact time and temperature, any functional barrier and the way the material is stored. The document that closes the circle is the Declaration of Compliance (DoC), which each link in the chain issues to the next one.
How to prepare the file
- State the food, the type of contact (direct or indirect), the temperature and the expected shelf life at the quotation stage. Without this information compliance is not assessed: it is hoped for.
- Ask for and keep the Declarations of Compliance for board, inks, varnishes, adhesives and film. The chain is worth as much as its weakest link.
- Check that every decorative component is covered: a foil or a scented varnish added at the last minute changes the documentary picture.
- If the project involves recycled fibre, put the barrier question on the table before the design, not after the cutting die is made.
- Consider sensory testing when the food is delicate: coffee, tea, chocolate and milk powder pick up odours that a chemical analysis does not catch.
What can go wrong
- "Mineral Oil Free" and "low-migration" are not synonyms. The first concerns the absence of mineral oils in the formulation, the second the overall migration behaviour. A food job may require both.
- Compliance is not a permanent stamp. Change the supplier, the varnish, the food or the shelf life, and the assessment has to be made again from scratch.
- The most underestimated risk is not on press, it is afterwards: set-off in the pile and on the pallet, and storage next to odorous materials. These are problems nobody looks for in the right place.
Frequently asked questions
- Are Mineral Oil Free inks enough to be compliant?
- No, they are one piece of it. Compliance concerns the whole pack — substrate, varnishes, adhesives, barriers — and the specific use. The ink is a condition, not the conclusion.
- What are MOSH and MOAH?
- Two families of hydrocarbons of mineral origin. They come from the mineral oils present in certain inks and from recycled fibres that contain residues of old print. They are the reason the mineral oil issue has become central in food.
- Who issues the Declaration of Compliance?
- Every operator in the chain issues it to the next customer, on the basis of those received upstream. Whoever packs the food is the last link and is answerable for the final assessment.