On November 26, 2021, the Federal Council of Germany is reported to have adopted the 21st Amendment to its Consumer Goods Ordinance that regulates the use of printing inks and varnishes. The adopted version is described as being very similar to the draft version last presented in 2016 (FPF reported) with the exception of an updated positive list of substances. The amendment entered into force on December 8, 2021, with a foreseen phase-in period of four to five years (until the end of 2025 and 2026), which will allow for the depletion of currently existing printing ink and article stocks. The ordinance applies to both printing inks and varnishes intended and not intended to come into contact with food. The included positive list lays out allowed monomers, additives, colorants, solvents, and photoinitiators for use in printing inks and varnishes. Food contact materials (FCMs) where migration of substances from the ink into the food is not possible, such as through the use of a functional barrier, are exempt from the regulation.

There is currently not an EU-wide harmonized regulation that addresses printing inks in FCMs, and the bloc has until now relied largely on Switzerland’s printing ink ordinance as guidance (FPF reported) to comply with the EU’s Framework Regulation 1935/2004 on ensuring the safety of FCMs.



German Federal Register (December 2, 2021). “Einundzwanzigste Verordnung zur Änderung der Bedarfsgegenständeverordnung.” (in German) (pdf)

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Keller and Heckman (December 13, 2021). “Germany Adopts Printing Inks Ordinance.”