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If Printing Ink Contacts Food, Must the Inks Be Food Safe?

March 11, 2014
Question 

My company is making tags in the shape of pop culture figures that attach to tea bags so that it appears the figure is holding the edge of the tea cup. Because the tag may come in contact with hot water, does the tag have to be printed with food safe ink?

Answer 

In the United States, the use of printing inks in food packaging materials must be manufactured under good manufacturing practices and be safe and suitable for their intended use. Additionally, if the use of the printing ink poses a "food additive" situation, then the use must be covered by a food additive regulation, an effective Food Contact Notification (FCN), a Threshold of Regulation exemption letter, or be exempted from the need for a clearance.

The act defines a food additive as "any substance the intended use of which results or may reasonably be expected to result ... in its becoming a component ... of any food... if such substance is not generally recognized ... to be safe" or prior sanctioned. (See Section 201(s) of the act.) In cases in which a printing ink is actually in contact with a food or beverage, it may be reasonable to expect migration of the ink to the food.

Inks typically are made up of colorants, binders, and carriers. No single regulation identifies the inks that are permitted for use on food packaging. For more information, see the PackagingLaw.com article, The Regulation of Printing Inks in the United States. You may wish to consider retaining qualified counsel to assist you in assessing your product prior to marketing it.