New JIG project on the declaration of conformity for printing inks from the Swiss Packaging Institute SVI.

With a transitional period until the end of January 2026, the Swiss Commodities Ordinance has been extended or tightened with regard to the “Declaration of Conformity for Printing Inks”. There are some ambiguities and regulations that are almost impossible to implement in practice. The SVI has therefore reactivated the JIG to draw up a checklist and a guideline or instruction for the declaration of conformity for printing inks. Representatives of all stakeholders along the value chain are invited to work together to develop valid and viable solutions. The aim is to implement a new, generally valid and accepted standard.

Switzerland has had its own regulation on the conformity of printing inks for packaging for several years now. On December 8, 2023, the Federal Food Safety and Veterinary Office (FSVO) issued a new regulation in the Swiss Commodities Ordinance, which came into force on February 1, 2024 and grants a transitional period until January 31, 2026. The new regulation expands the Consumer Goods Ordinance to include Annex 15 “Declaration of Conformity for Printing Inks”. This Annex 15 regulates the declaration of conformity for printing inks in accordance with Article 35a paragraph 2 and must now contain the relevant information for each manufacturing stage.

The current CH regulation comprises a List A and a List B. Substances on List A have been tested for safety and may be used. List B substances may also be used, but the manufacturer must prove their safety in individual cases on the basis of model calculations. The last version of these two lists, dated 1.10.2022, contained a total of 5345 substances. The new regulation removes List B, leaving only around 1100 substances that may be used in the manufacture of printing inks. According to the printing ink industry, it is not impossible to produce printing inks with these approximately 1100 substances from list A, but possibly not in the current variety and with the properties we are used to. In addition, Germany has now also published a positive list on the conformity of printing inks for packaging in 2021, which contains only 594 substances, although it was previously stated that the German and Swiss lists should be harmonized. This has not happened and so the question arises as to how this will be handled from 2026.

In addition to harmonization between the EU, Switzerland and the printing ink industry, the JIG will also deal with the evaluation of substances. The main focus here is on non-listed compounds and so-called NIAS (non-intentionally added substances), i.e. unintentionally introduced substances that are largely produced by chemical reactions during printing ink production. In order to evaluate these substances, the printing ink industry uses data from EU chemicals legislation. In practice, this leads to the nonsensical regulation that the same substances are permitted as NIAS but prohibited as intentionally added printing ink components. In addition, there is the entire subject area of potentially “mutagenic”, “carcinogenic” or “reprotoxic” substances (CMR substances).

The Swiss Packaging Institute SVI has reactivated the Joint Industry Group for Packaging Safety (JIG) to find solutions to this problem. In the JIG, the relevant interest groups, in particular the packaging industry along the value chain, authorities and law enforcement as well as industry associations, are to work together to develop economically viable solutions and concepts for the entire packaging industry. The new JIG on the topic of printing inks for packaging started with a kick-off meeting in Olten on June 19, 2024. Around 25 representatives from the printing ink industry, the packaging industry and the authorities were present.

The aim of the JIG is to provide our industry with the necessary information and tools so that they can guarantee the safety of packaging efficiently and sustainably. The SVI is therefore calling on companies in the packaging industry along the value chain to take part in the discussion in the JIG. To this end, a subscription form for the “JIG project declaration of conformity for printing inks” was sent out on July 1, with which companies can declare their cooperation and support the specialist group financially. The funds required for the project total around CHF 35,000. The contributions of the interested companies are graded according to their size.

Swiss Packaging Institute SVI

Link to the project tender