During the Global Food Contact conference, which took place May 14 to 16, 2013, Sebastian Gierisch of the Michael Huber München (MHM) Holding in the Huber group summarized industry’s complaints with respect to the new German ordinance on printing inks. According to Gierisch, the German Association of Food Law and Food Science (BLL) demands direct and indirect food contact inks to be regulated separately. The BLL criticizes that neither the legal procedure for arriving at the proposed positive list nor rules for migration testing are specified in the draft ordinance. Further, the BLL argues that the notification duties and the rules for declarations of compliance are impractical, and that the transitional period of only one year is too short.
The latest draft ordinance on printing inks amending the German Consumer Goods Ordinance (BedGgstV) was passed to the German Ministry for Nutrition, Agriculture and Consumer Protection (BMELV) in February 2013. It covers printing inks on the food contact surface as well as the non-food contact side of packaging. The new ordinance on printing inks will contain a positive list of evaluated substances with specific migration limits and of substances falling under the overall migration limit of 10 mg/dm2. Non-evaluated substances will be limited to a detectable level of 10 ppb.