Industry Insight 15 April 2025 · 2 min read

Low-migration inks, FSC® board and what food brands actually need to document

Food and cosmetics packaging carries obligations that general packaging does not. Here is the paperwork trail we issue, and the questions a brand's compliance team should be asking its supplier.

Low-migration inks, FSC® board and what food brands actually need to document

When a client moves from general retail packaging into food or cosmetics, the specification conversation changes. Print quality still matters, but it stops being the deciding factor — migration limits and documentation do.

The core issue with printed board. Conventional offset inks contain components that can migrate through a paperboard substrate into food over time. For direct-contact packaging this is clearly regulated. For indirect contact — a printed carton around a sealed inner bag or a jar — the requirement is lower but not zero, and some markets apply stricter interpretation than others.

What we change in production. For food and cosmetics work we move to low-migration ink systems and water-based varnishes rather than conventional solvent coatings. Where a grease barrier is needed we use a coated or lined board rather than relying on the print. Window film is specified as PET or compostable PLA depending on the market. None of this is exotic; the point is that it has to be decided at specification stage, not after the artwork is approved.

The documents we issue. A brand's compliance team should be able to file the following with the product:

- Board grade and supplier declaration, including FSC® chain-of-custody transfer documents where certified board is used
- Ink and coating declaration confirming low-migration suitability for the intended contact type
- REACH and RoHS statements covering inks, coatings, adhesives and inserted components
- A food-contact declaration naming the specific contact scenario the materials are approved for

Questions worth asking any supplier. What contact type is this declaration written for? Which market's regulation does it satisfy? Can we see the board supplier's own declaration rather than a general statement? If the answers are vague, the paperwork will not survive a retailer's compliance review.

The honest limitation. Certification applies to the materials and the process as specified. If a client later changes an ink, a coating or a film to save cost without telling us, the declarations no longer describe the product. This is why we reissue documents whenever the specification changes — and why we ask to be told.

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