Are your food labels legal?

The EU 10/2011 regulation, on plastic materials and articles intended to come into contact with food, came into force on 1 January 2013. And it seems most self-adhesive label printers know it judging by the rise in requests for Declarations of Conformity (DoCs) we are receiving at UPM Raflatac.

EU 10/2011 supports brand owners’ and retailers’ duty of care to their customers, as a further measure to protect the quality and safety of food. While EC No 1935/2004 applies to food packaging generally, the EU 10/2011 regulation 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 Declarations of Conformity (DoCs) stating which controlled but authorized substances are present.

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.

Chain of documentation: raw material to packer

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.

Printers supplying labels into the EU food industry need to be proactive in obtaining and supplying the right documentation. Obtaining the necessary Declarations of Conformity from their labelstock suppliers shouldn’t be too difficult. UPM Raflatac, for example, supplies DoCs featuring a high-quality of information in full regulatory compliance with EU 10/2011; for our faces, adhesives including special food grades and also backings where multi-layer label constructions are concerned.

Producing DoCs to a satisfactory standard is a level playing field for all sizes of operation. Having DoCs in good order ensures the continued viability of valuable partnerships, and ultimately works in the interests of consumer safety.

Jay Betton

Business Segment Manager,
Food and Retail labelling,

UPM Raflatac EMEA