EuPIA publishes Swiss ordinance guidance

EuPIA has published guidance on the Swiss Ink Ordinance and declaration of conformity requirements, clarifying the role of Statement of Composition documents in the packaging supply chain.

Since 2017 the Swiss Ordinance (Ordinance on Materials and Articles in contact with Food SR 817.023.21) has set standards for printed food packaging materials in Switzerland. With the revision from December 2023, Swiss authorities implemented major changes including the requirement for a declaration of conformity. In line with the provisions of the EU food contact legislation and the relevant guidance documents of the Council of Europe, each actor in the value chain has to provide the information needed by the next actor for compliance work.

For printing inks, EuPIA members already provide what is called a Statement of Composition. This SoC lists those substances with the potential to migrate along with the applicable migration limits and the amount of that substance in the ink or coating, providing all the information the converter needs.

'Our SoC also mirrors what has been agreed within the Packaging Ink Joint Industry Task Force, an industry forum created by all stakeholders involved, and what is written in their Guidance on Information and Transparency,' explained Christof Walter, EuPIA's food contact manager.

Under the revised Swiss Ordinance, the SoC remains the relevant tool to pass the adequate information from the ink manufacturer to the converter. An SoC prepared according to the recommendations and standards of EuPIA provides all information that has to be communicated for the stage of the ink production as set out in Annex 15 of the SIO and becomes an 'ink DoC'. The converter then needs to issue a 'converter DoC' by including additional parameters like surface-to-volume ratio, film weight and substrate.

This information is part of the overall risk assessment of the final article and can only be provided by the converter as the ink manufacturer might not know about all end applications for the ink.

EuPIA and VSLF have issued additional guidance to provide further clarity on this and other questions.