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Food Packaging Inks for Indirect Food Contact

Who hasn’t poured ketchup onto the tray liner to dip French fries?

Those tray liners used in fast food restaurants aren’t intended as direct food surfaces, but sometimes are called upon to fulfill that function.

Other food service and packaging products may be classified as indirect food contact items. These include things like drinking cups, paper plates and disposable napkins. Although some of these items aren’t intended for direct contact with food, they must still be printed with inks that meet certain standards to ensure product safety. Indirect food contact occurs when the printed area of the packaging is not specifically intended to make contact with food under normal foreseeable conditions. 

But just because a product may not be designed for direct food contact, it can still happen.

Nested products, such as paper cups or French fry holders are other common instances of incidental contact. Although there is typically no printing on the inside of these containers, the printing on the outside comes into direct contact with the insides of others when they are stacked for shipping and storage. There is potential that migration or ink set off could take place from the outside of one container to the inside of the next.

Why Go No-Tox?

While regulatory agencies may apply a complex hodgepodge of different standards to different items, our recommendation to food packaging printers is to: Keep it Simple! Use a no-tox ink to gain that extra margin of safety and avoid the need for migration testing or functional barriers.

For many food manufacturers and packagers, this approach is an easy decision that can mean significant time and cost savings, and reduced risk of out-of-spec product. 

If food additives are part of a contacting surface, they must either migrate at or below TOR levels. If migration is higher than the TOR, then an effective functional barrier must be present.

For example, an OPV (overprint varnish). In this case, testing will be needed to demonstrate it doesn’t allow migration above the TOR,  is devoid of pinholes and is resistant to all of the end use conditions. It can be very difficult to ensure a consistent ink film each time the job is printed and that the varnish is completely resistant to any food it may contact.  Unfortunately, most effective functional barriers are film laminations which add to the weight & cost of a package and make products far less recycling friendly. 

We recommend that in any situation where indirect food contact is a possibility, the printing ink used on these single use items should meet the highest denominator to eliminate risk and reduce the need for additional testing and reformulation. 

Ready to talk about your next food packaging print project? Contact us!


Leyna Force has a BS in Chemistry from Kutztown University and an MBA from DeSales University.  Leyna joined the No-Tox Products Division of Colorcon in 2006 as a Research Scientist. Over the past fifteen years she has held many technical positions within the company.  Her current role is the Manager of Laboratory Services where she oversees the No-Tox Technical Services, Quality Control, and New Product Development laboratories. 

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