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We want to make sure that our inks do not contain any raw materials or impurities that could migrate from the packaging into the food. In theory, this kind of migration can occur when the packaging is stacked after printing, for example. If the printed outer side of one box touches the inside of the next one, the ink can be transferred. And if critical components get on the inside of the packaging, the food is likely to be contaminated. There was a case in 2005 when a photoinitiator for UV-cured printing inks was found in the packaged food, which caused alarm in the industry. In the end it turned out that the substance was not overly critical, but it certainly served as a wake-up call.
It resulted in a complete reorganization of the market in terms of food packaging and migration. Today the “Swiss list” – a white list for substances – serves as the definitive guideline. It is now internationally recognized and divides raw materials that are suitable for low-migration printing inks into two groups. Group A contains substances that have already been tested and for which specific limit values have been defined. The much larger Group B contains the substances that have not yet been (sufficiently) tested. A limit value of 10 ppb has been defined for these substances. This is the maximum amount that may be transferred to a packaged food item.
Exactly, and it’s also extremely difficult to detect such a small quantity. By way of comparison, imagine you have a crowd of several thousand people; 100 of them leave the group and go hide all over the world among a population of nearly eight billion – how would you find them? That’s how difficult it is to detect the tiny quantities we’re talking about. To avoid this problem or make the whole thing less of an issue, we decided to take a completely different approach. We want to eliminate all critical substances from our products for indirect contact with food. To this end, not only have we developed special formulations for low-migration printing inks, but we have also set up a separate production line for them. This has enabled us to establish production processes that minimize and – to the greatest possible extent – rule out any chance of cross contamination.
First of all, we use physically separate production areas. Our FPG printing inks are produced in line with the principles of good manufacturing practice (GMP) in a specially designated space which is structurally separate from the other production areas. Secondly, we use different production containers depending on the chemical basis as it is important to ensure that raw materials from different systems do not come into contact with each other here either (for example UV-cured systems and solvent systems).
Low-migration inks for UV or LED curing processes make up around 95 percent of our production, so we have two containers for these products. Then we have one each for water-based, solvent-based, and plant oil–based paint systems. We are currently using one mixer for all of our low-migration production processes. We have therefore developed a special cleaning process for the mixer which takes place in line with strict specifications and prevents any contamination. The cleaning results are checked according to an equally strict protocol.
Customers receive two certification documents with our FPG products: a certificate of non-objection and the SoC (Statement of Composition). The certificate of non-objection is based on an analysis by an external institute and confirms that our printing ink has undergone the standard assessments and has been declared as low-migration. The SoC provides a summary of all constituents. This document, however, is only intended for the EHS manager in the customer’s company.
We use failure mode and effects analysis, or FMEA. This is a recognized method and it forms an important part of our certified quality management system. We use it to analyze the likelihood of errors occurring and being detected. We carry out this analysis at least every two years – all of the processes that are relevant to the production and filling of our inks for food packaging must be scrutinized and evaluated.
It is true that our FPG products are in a higher-priced market segment. But for our customers, the extra expense is worth it. Firstly, it means that they can guarantee full traceability for their own customers with regard to low-migration inks and, secondly, it enables them to exploit an attractive, fast-growing market niche.
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