Food contact labels
A label that may touch food is a different specification from one that never will. Here is what actually changes, and what to ask any label supplier before you order.
What makes a label a food contact label
Most labels on a food pack never touch the food. They sit on the outside of a jar, a film lid or a carton, with the packaging itself between the label and the contents.
A food contact label is one where that barrier is not there, or cannot be relied on. The obvious cases are labels applied directly to unwrapped produce or to the inside of a pack.
The less obvious ones matter more, because they are the ones people get wrong: a label on a thin or permeable film, a label on a pack so small that the label is a meaningful share of its surface, and reels wound face-to-back where ink on the front can transfer onto the surface behind it.
Under the retained EU framework regulation on materials and articles intended to come into contact with food (Regulation (EC) No 1935/2004) the principle is straightforward, even if the detail is not: such materials must not transfer their constituents to food in quantities that could endanger human health, change the composition of the food, or spoil its taste or smell. Good manufacturing practice for these materials is covered separately by Regulation (EC) No 2023/2006.
What changes when a label is food contact
Four decisions change: the ink, the way the reel is handled, the adhesive, and the paperwork that goes with it.
| Element | What changes |
|---|---|
| 01Printing inks | Printing inks for food packaging are selected for low migration and are formulated against industry guidance rather than picked for colour alone. The relevant reference points are the Swiss Ordinance list of permitted substances for food packaging inks and the EuPIA guideline on printing inks for food contact materials. This is a specification decision, made at quotation. |
| 02Set-off on the reel | On a reel, the printed face sits against the back of the material wound above it, and ink components can transfer across that contact. Far from being out of scope, this is the exact scenario the Good Manufacturing Practice regulation legislates for: its annex on printing inks names set-off in the stack or the reel specifically, and it governs how printed material is handled and stored, not only how the ink is formulated. Which means our reel handling and our warehouse are inside the scope of a food contact law, not outside it. |
| 03Adhesive | The adhesive is part of the construction and part of the question. Food contact grades exist across the range, including chilled and freezer adhesives, but a general purpose permanent is not automatically suitable simply because the face material is. |
| 04Documentation | Compliance is evidenced on paper as well as in practice. If your technical team needs a declaration of compliance for the material, or supporting documentation for your own audit file, say so when you ask us to quote and we will confirm what can be supplied for the construction in question. |
What to ask any label supplier
Worth asking us, and worth asking whoever you use now. A supplier who cannot answer these quickly is not thinking about your application.
- Is this construction intended for food contact, or only for the outside of the pack?
- What documentation can you supply for the material, and how quickly?
- How is set-off on the reel accounted for in this specification?
- Is the adhesive suitable for the temperature the pack is filled and stored at?
- Are you certificated to a recognised packaging standard, and to what grade?
- Who signs the artwork off, and where is that record held?
One thing we will not do is tell you your pack is compliant. Responsibility for the compliance of a finished food product sits with the food business placing it on the market, and it depends on the food, the pack and the conditions of use as much as on the label. What we can do is manufacture to an agreed specification, be clear about what that specification is, and give your technical team what they need to make their own assessment.
Certification
Grade A BRCGS Packaging certification.
Independently audited certification to the BRCGS Packaging Materials standard. For a technical manager approving a new supplier, that is the difference between taking our word for it and having third-party evidence.
Reviewing your label supplier?
Let's talk.
Tell us what you make, how it is packed and what your current labels are not doing. We will come back with a specification and a straight quote.