Plastics packaging and materials

At J.S. Hamilton, we conduct various tests for plastic packaging and materials:

  • Overall and Specific Migration into all food simulants
  • Specific migration of:
    • Primary Aromatic Amines (PAAs) and Annex II Metals,
    • Plasticizers, antioxidants, monomers and other additives acc. EU 10/2011 Annex I and Swiss Ordinance,
    • Non-Intentionally Added Substances (NIAS) Screenings by methods: GC-MS/FID, LC-QToF-MS, Headspace-GC/MS
    • Bisphenols A, B, S, F and epoxy resin derivatives BADGE, BFDGE and NOGE in coated materials, plastics and adhesives,
    • Mineral oils (MOSH/POSH & MOAH),
  • Isocyanates and azo-dyes,
  • Set-off effect of printing inks and specific migration UV-initiators, acrylates, BHT, PAAs, etc.,
  • Sensory analysis acc. DIN 10955, EN 1230-1/-2,
  • Colorfastness acc. EN 646, DIN 53160-1 / -2,
  • Barrier properties against gases: oxygen (OTR), water (VWTR), CO2TR.

The most comprehensive specific EU measure is Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food. It sets out rules on the composition of plastic FCMs, and establishes a Union List of substances that are permitted for use in the manufacture of plastic FCMs. The Regulation also specifies restrictions on the use of these substances and sets out rules to determine the compliance of plastic materials and articles.

OVERALL & SPECIFIC MIGRATION

Food packaging can be a source of chemical food contaminants.

The chemicals transfer from FCMs into food is called migration. The extent to which migration occurs depends on various factors: the physico-chemical properties of the migrant, of the packaging material, and the food (e.g. fat content, acidity), temperature, storage time, size of the packaging in proportion to the foodstuff volume (smaller size packaging has a larger surface to volume ratio).

Food simulants acc. (EU) 10/2011
A – Ethanol 10% (hydrophilic food)
B – Acetic acid 3% (hydrophilic food pH<4.5)
C – Ethanol 20% (alcoholic more lipophilic food)
D1 – Ethanol 50% (lipophilic/alcoholic food; oil in water emulsion), milk products
D2 – Vegetable oil; (lipophilic food; surface free fats) or alternative D2 food simulants Ethanol 95%, isooctane
E – Poly (2,6-diphenyl-p-phenylene oxide) (dry food), Tenax®, MPPO

 

The types of chemicals that can migrate from packaging into food are highly diverse and depend on the type of packaging material. For inert materials (stainless steel, ceramic, glass), only chemicals from the inside surface, directly in contact with the foodstuff, can migrate. Chemical diffusion from within the packaging material or from the outside (printing inks, adhesives) is not possible.

Non-inert materials, like paper and board or plastics, can be a direct source of migrants. Chemicals may also migrate from the outside through the packaging. An example are printing inks compounds that may migrate through paper into dry foods.

A special case of migration is SET-OFF migration, when outside layer of a food packaging (printed) can transfer chemicals to the inside, direct food contact layer when both layers are in direct contact with each other. Set-off migration occurs when printed film foil is stored in rolls, or when paper cups are stacked into each other.

The most comprehensive description and detailed migration testing rules is given by Plastic Regulation EU 10/2011. Safety assessment mechanism  of plastic materials is based on use of migration limits. These limits specify the maximum amount of substances allowed to migrate to food.

For the substances on the Union list the Regulation sets out Specific Migration Limits (SML). These are established by EFSA on the basis of toxicity data of each specific substance. To ensure the overall quality of the plastic, the overall migration to a food of all substances together may not exceed the Overall Migration Limit (OML) of 60mg/kg food, or 10 mg/dm2 of the contact material.

Although migration testing in the food prevails, migration is usually tested using ‘food simulants’. These simulants are representative for a food category, e.g. Acetic acid 3 % is assigned for acidic foods, 50% Ethanol for milk and dairy products. Food simulants are used as substitutes for food due to the simplification of chemical analysis. Chemical detection and quantification requires specific analytical methods for each chemical of interest, specially developed for each food and food simulant type.

The migration testing is done under standardized time/temperature conditions, representative for a certain food use, and covers the maximum shelf life of packed food and special thermal treatment conditions.

To ensure the safety, quality and compliance of plastic materials, adequate data on the composition of (intermediate) materials has to be communicated via the manufacturing chain, up to but not including the retail stage. For this purpose a Declaration of Compliance (DoC) needs to be provided. The DoC is based on supporting documentation which documents the reasoning on the safety of a plastic food contact material, and which must be provided to enforcement Authorities on their request. The supporting documentation also provides an important link to the manufacturer’s responsibility under GMP (Regulation (EC) No 2023/2006).

 

NON-INTENTIONALLY ADDED SUBSTANCES

During the life cycle of food contact materials, unexpected and potentially harmful substances may migrate from packaging materials to food products.  The term NIAS was introduced for plastic FCMs in the legal context (EU) 10/2011. However, NIAS are not limited to plastics but also occur in all other non-plastic FCMs. Article 3(9) of EU 10/2011 defines NIAS as an impurity in the substances used or a reaction intermediate formed during the production process or decomposition or reaction product. Thus NIAS have various sources, it may be side products, breakdown products, and contaminants. Side products are often formed during the production of starting substances and all further manufacturing stages. Polymers, fibers as well as additives (e.g., antioxidants, UV-stabilizers) are often degraded during manufacture and use, thus leading to various different breakdown products. Starting substances often contain impurities or environmental contaminants which may remain in the final FCM. Processing and especially recycling can also introduce many different contaminants in FCMs. Typical recycling-related NIAS are mineral oil hydrocarbons (MOHs), bisphenols, phthalates, and photoinitiators in recycled paper or flavor compounds, oligomers, and additives in recycled plastics.

According to the legislation, NIAS have to be assessed using scientifically recognized principles of risk assessment. Non-Intentionally Added Substances have to comply with the general safety requirements of Article 3 of Regulation (EC)1935/2004  and are subject to a risk assessment by the business operator in accordance with Article 19 of Regulation EU 10/2011.

Has this article been interesting to you? Contact us for more detail – or schedule tests for your plastic packaging and contact materials.

Printed packaging and FCMs

Food packaging is very important for food producers. The visual aspect of packaging is a very powerful tool, so that consumers consider a brand name as an established value. In the process, the chosen varieties of ink play a crucial role. The choice may not only be based on marketing strategy. Still, the potential health risks that might result from the migration issues of the ink components have to be taken into account. Printing inks used in food packaging materials contain substances that might migrate, such as raw materials, photoinitiators and acrylates, by-products of hardeners, solvents or products of degradation and reaction between inks compounds under storage and application conditions. If you are a food manufacturer or packaging manufacturer, you need to comply with rules we describe below.

More than five thousand different chemicals can used in the production of printing inks. Some substances are evaluated by EFSA, Swiss Ordinance, German Printing Inks Ordinance or EuPIA, and restricted by a Specific Migration Level (SML). In addition, most of the printing ink chemicals on the industry inventory lists are not fully risk assessed and toxicological data may be unavailable. However, producers are obliged to demonstrate safety in use, and the public food inspection has to control it.

LEGAL REQUIREMENTS:

The ink itself does not need to be tested as such, since its composition may change during the printing process. In addition, the substrate influences the migration properties of the components of the ink. Regulation (EC) No. 1935/2004 requires that the finished article for food contact materials must be tested and / or evaluated under real conditions of use. In addition, the in-house control based on declarations of compliance and supporting documentation are important prerequisites for the limitation of this contamination and to ensure compliance with the EU legislation. This is a general point of quality assurance, even though the European legislation does not specifically regulate printing inks.

THE GENERAL AND BASIC REQUIREMENTS GIVEN BY THE ANNEX OF REGULATION EU 2023.20076 (GMP) ARE:

  • Printing inks applied to the non-food-contact side of materials and articles shall be formulated and/or applied in such a manner that substances from the printed surface are not transferred to the food-contact side.
  • Printed materials and articles shall be handled and stored in their finished and semi-finished states in such a manner that substances from the printed surface are not transferred to the food-contact side:
    • through the substrate or
    • by set-off in the stack or the reel, in concentrations that lead to levels of the substance in the food are not in line with the requirements of Art. 3 of Regulation (EC) 1935/2004.

Transfer of printing ink components from a printed packaging material or article into food or food simulant may occur either directly as migration through the substrate, via contact to the reverse side in a reel or stack (known as “set-off migration”) or by gas phase transfer.

Migration of printing ink components depends on:

  • ink and varnish formulation,
  • substrate, shape and design of the packaging,
  • printing process conditions (drying, speed, efficiency of lamps, etc.),
  • real / intended usage (type of food, sterilization, pasteurization),
  • storage conditions (temperature, time, pressure).

Invisible SET-OFF migration

Although it is not visible to the human eye, ink set-off can occur on the reverse side of printed articles, foils, containers, cups, and other packaging storage and transported in stacks or reels after printing. This creates a danger, that substances could be transferred to the unprinted inner side of the packaging that contact with the packed food. However, migration testing and/or Worst-Case Calculations can measure and quantify this phenomenon and verify safety of finished packaging.

EUROPEAN LEGISLATION:

  • Framework legislation: Regulation (EC) No 1935/2004of the European Parliament and of the Council of 27 October 2004 on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC,
  • Regulation on Good Manufacturing Practices: Regulation (EC) No 2023/2006of 22 December 2006 on good manufacturing practice for materials and articles intended to come into contact with food,
  • Plastic materials: Regulation (EU) No 10/2011of 14 January 2011 on plastic materials and articles intended to come into contact with food,
  • Swiss Ordinance (SR 817.023.21) of the FDHA on materials and articles intended to come into contact with foodstuffs,
  • 21st Amendment to the German Consumer Goods Ordinance (Printing Inks Ordinance), entered into force on December 8, 2021,
  • EuPIA guidelines on printing inks for Food Contact Materials.

TESTING OFFER:

  • Overall and Specific Migration into all food simulants
  • Specific migration of:
    • Primary Aromatic Amines (PAAs) and Annex II Metals
    • Photoinitiators (UV initiators) and acrylates
    • Plasticizers, antioxidants, monomers and other additives acc. EU 10/2011 Annex I and Swiss Ordinance
    • Specific migration of Non-Intentionally Added Substances (NIAS):
  • GC-MS/FID Screening
  • LC-QToF-MS Screening
    • Mineral oils (MOSH/POSH & MOAH)
  • Hedsapace-GC/MS Screening (VOCs, solvents residual)
  • Sensory analysis acc. DIN 10955, EN 1230-1/-2
  • Simulation of SET-OFF storage effect in reels or stacks
  • Worst-case calculations

Trainings

ABOUT TRAINING COURSES

J.S. Hamilton Poland conducts prestigious seminars, trainings, workshops and laboratory classes aimed at the food, cosmetics and household chemistry, packaging and environmental protection sectors. The participants of training courses can be: technologists, quality and laboratory workers, production department employees, personnel responsible for quality and product safety, managers and employees of legal or marketing departments. Everyone can raise their professional competence, improve work efficiency and better prepare themselves to carry out their professional tasks at a relatively low cost of training. J.S. Hamilton Poland is registered in the Register of Training Institutions (RIS) and the Database of Development Services – PARP, which allows the participants of our training courses to obtain co-financing of training from public funds.

Moreover, the competence of the trainers and the quality of the trainings conducted have been confirmed by the ISO 9001: 2015-10 Certificate in the scope of training and development and consulting services.

AREAS OF TRAINING

Our offer includes training in areas such as:

  • Food safety and quality, including training courses and workshops covering: sensory evaluation, microbiological testing, allergen and GMO analysis, food safety management systems, HACCP, ISO 22000, FSSC, BRC and IFS systems for retail chains, commodity and food quality training;
  • feed safety, the implementation of HACCP procedures, the GMP+ system, the legal aspects of trade in feed and provisions relating to its labeling;
  • Packaging, including: training on BRC food packaging safety, global and specific migration, eco-design, life cycle and packaging recycling;
  • Cosmetics, including: training and workshops on sensory and microbiological analysis of cosmetics, legal requirements for safe use and labeling of cosmetic preparations;
  • Environmental protection, including: training and workshops on sewage sludge management, packaging waste management, municipal tasks in the field of environmental protection, charges for using the environment;
  • Chemicals and petroleum products, including: training in liquid fuel sampling light fuel oil sampling, test methods for fuel oil and liquid fuels, quantity accounting for fuel oil.

TRAINING STAFF

Training courses are conducted by lecturers drawn from our own staff, using their extensive knowledge and experience. We also invite experts and auditors of leading certification companies, employees of consulting companies from Poland and abroad to give lectures.

The mission of our company is to take care of the welfare of our customers by satisfying the educational needs of the participants of our seminars and training courses and by organising training courses at the highest level.

TRAINING PACKAGES

We offer training packages, covered by a special discount, which will allow you to obtain the necessary knowledge in a given subject. After each training included in the package you receive a certificate confirming your participation in the training, and completion of the whole package guarantees obtaining a specialist certificate.

CLOSED TRAINING

In order to meet the expectations of our clients, we organise training adapted to the needs and specificity of the company. Each training included in the training schedule can be realised as a closed training on customer’s request. This also applies to training courses which are not listed in the training schedule.

Training courses and workshops are organised at a time and location determined by the client. Programs are usually priced according to the number of days and the number of participants so that the company can save considerable sums of money in the case of larger groups and reduce travel and accommodation costs by organising the training at its own premises. Each participant receives training materials. The training ends with a certificate or attestation confirming the highest quality of training.

QUALITY AND FOOD SAFETY MANAGEMENT ACADEMY J.S.HAMILTON POLAND

The Training and Audit Department of J.S. Hamilton Poland also invites for a cycle of training courses, which in a comprehensive way prepares present and future employees of quality departments of food industry companies for the role of managers responsible for the development, implementation and improvement of food and packaging safety and quality management systems.

In one semester (165 hours), students of the Academy acquire knowledge in the areas of food contaminants, sensory analysis, packaging regulations, quality management system requirements and food safety. Our lecturers, experienced auditors and managers of quality departments in food industry companies, share their practical knowledge with the students on how to carry out and document audits and interpret legal provisions.