IS 15495: Understanding the regulation

In India, the Food Safety and Standards Authority of India (FSSAI) is responsible for protecting and promoting public health through the regulation and supervision of food safety. FSSAI has been established under the Food Safety and Standards Act, 2006. FSSAI is now revamping their standard on packaging and labeling, and is laying more emphasis on packaging safety by bringing a specific regulation focused on food safety aspects of the packaging material. The standard prescribes that any material used for packaging, preparation, storing, wrapping, transportation and sale or service of food shall be of food grade quality (‘Food grade’ refers to materials made of substances which are safe and suitable for their intended use which shall not endanger human health and bring change in the composition of food or organoleptic characteristics). FSSAI has always promoted the principle of self-discipline in the industry, which eventually helps the brand owners to apply best practices available globally and produce safe products for the consumer.

Packaging regulation prescribed by FSSAI is a more stringent version of the current regulation and now encompasses more elements such as paper, metal, packaging inks etc. FSSAI now prescribes that printing inks for use on food packages shall conform to IS 15495. The standard is being developed by Bureau of Indian Standards (BIS) and will be mandatory post FSSAI notification of the regulation.

Packaging supply chain needs to understand the standard in order to ensure the adherence to the prescribed standard. Hence, Siegwerk being in the forefront of championing the cause of food safety, has made efforts to document the standard for the easy understanding and implementation.

Packaging inks conformance to IS 15495:
The Indian Standard IS 15495:2004 ‘Printing Ink for food packaging – Code of Practice’ prescribes guidelines for printing inks for use in food packages. The standard differentiates between four categories of printing inks and gives guidance on the formulation of the respective inks:

1. Printing inks on external (secondary/tertiary) food packaging: They can be formulated freely, but must not contain substances from the exclusion list and must not contain toxic substances. In the case, that a functional barrier does not exist, bleeding dyes and coloring agents need to be avoided.
2. Printing inks on immediate food wrappings: Those must be applied to the outside of the food wrapper, comply with the exclusion list and must not contain toxic substances. Inks are to be printed in such a manner as to avoid set-off. The final intended articles need to be manufactured in a manner that under normal or foreseeable condition of use, they shall not transfer their constituents to the food in quantities, which may endanger human health, cause a deterioration in the organoleptic characteristics or an unacceptable change in the nature, substance and/or quality of the food. In the case, that a functional barrier does not exist, bleeding dyes and coloring agents need to be avoided.
3. Printing inks for direct food contact: They must be formulated only with food additives under the appropriate regulation of the Government of India. The final intended articles need to be manufactured in a manner that under normal or foreseeable condition of use, they shall not transfer their constituents to the food in quantities, which may endanger human health, cause a deterioration in the organoleptic characteristics or an unacceptable change in the nature, substance and/or quality of the food. In the case, that a functional barrier does not exist, bleeding dyes and coloring agents need to be avoided.
4. Printing inks for disposables (e.g. paper plates, drinking straws or table napkins): Those inks must not contain substances from the exclusion list or those, which are otherwise known to be toxic. Moreover, they shall be formulated to avoid bleeding onto the food.

Specified requirements across the supply chain stakeholders:

Ink manufacturer:

• Ink manufacturers are responsible to formulate packaging inks by using only raw materials other than those known to be toxic, carcinogenic, sensitizing or mutagenic, primarily governed by the exclusion list as per Annex A.
• Ink manufacturers are expected to take all necessary precautions to meet the guidelines of the standard.
• Ink manufacturers shall inform the converter and print buyers on the suitability of ink type towards the packages of food and the norms followed in formulations as per the requirement.

Printer/converter:

• The printer and converter is finally responsible for manufacturing and storage of the food packages in such a manner by which all preventable transfer of material from the ink or coating to the food content is avoided, even if such transfer is unobjectionable on the grounds of health, odor and flavor.
• The printer needs to ensure that the storage environment should be free from potential volatile contaminants, which could adversely affect the organoleptic characteristics of the food.
• For immediate food wrappings and direct contact applications the final intended articles needs to be manufactured in such a way, that under normal or foreseeable condition of use, they shall not transfer their constituents to the food in quantities, which may endanger the human health, cause a deterioration in the organoleptic characteristics or an unacceptable change in the nature, substance and/or quality of the food.
• For immediate food wrappings and direct contact applications the printer needs to establish appropriate controls to avoid set-off in the printing process.
• The converter needs to perform adequate analysis for the specific application in context of validating the bleeding capacity of dyes and pigments used in the inks.

Print buyer/brand owner:

• Print Buyers need to design the packaging with the restriction of printing in mind.

• For immediate food wrappings and direct contact applications the final intended articles needs to be manufactured in such a way, that under normal or foreseeable condition of use, they shall not transfer their constituents to the food in quantities, which may endanger the human health, cause a deterioration in the organoleptic characteristics or an unacceptable change in the nature, substance and/or quality of the food.

• Relationship between the press speed and the curing/drying power needs to be fully understood to ensure that an adequate curing/drying takes place.

• For immediate wrappers, the print buyer needs to recommend substrates with sufficiently low permeability to prevent migration.

It is very important to understand that packaging safety can only be implemented when packaging supply chain partners share information among each other and follow an integrated approach. Integrated Packaging Supply chain is the key to success of packaging safety implementation.

Authored by Jatin Takkar – head of product safety and regulatory, Siegwerk India – for ease of understanding the standard by the converters.