Printing Inks - Issues, Guidance and Regulations

Printing Inks – issues,
guidance and regulations

Chris Whitehead
Director – Sustainability and Regulatory Affairs
Packaging and Narrow Web
February 2010
Topics
► Flint Group Overview

Global
Packaging & Narrow Web
► Food Packaging and Legislation
Including GMP and Traceability demands
► REACH
Print supplied into Europe is an Article
• Few demands
► Carbon Footprint & Sustainability
2
Chris Whitehead – February 2010
► A leading supplier to the
Printing and Packaging
Industries.
► #1 or #2 supplier in every
major market segment we
serve.
Most complete portfolio of product offerings
► Inks for all types of substrates and applications

Flexographic Heatset Coldset Web Offset Sheetfed Offset
Gravure Energy Curable Specialty Printing
► Lithographic printing blankets and sleeves

► Sleeves for flexo printing, photopolymer printing plates for flexo and letterpress
applications
► Full range of OEM image transfer components used for digital printing
(electrophotography)
► A full range of press room chemicals
► Colorants for use in graphic and non-graphic applications.
4
How was Flint Group created?
► Nov. 2004 CVC acquired ANI Inks and BASF Printing Systems.
► Integration of these two businesses created XSYS Print Solutions,

the number two ink supplier in Europe.
► Sep. 2005 XSYS acquired Flint Ink, a privately owned company with
operations in USA, Europe, Latin America, Asia and India/Pacific.
► Integration of these businesses lead to creation of Flint Group,

number two ink supplier worldwide.
► May 2007 Flint Group acquired Day International, a leading supplier

of printing blankets and consumables.
5
Powerful Roots – Sources of Expertise
6
nternational Corporation
Morrison
Inks
Inks
Chemical
s News/Publicatio
n
B&T
CQIB
NT
INENT
BASF
O
NA Graphics
I N KS
Temple Inks
7
Top 7 Printing Inks Manufacturers
Net Sales 2007

€ million
1 DIC / Sun Chemical 4,000
2 Flint Group 2,283
3 Toyo Ink 878

4 Siegwerk 850
5 Sakata INX 800
6 Huber Group 750

7 Tokyo Printing Ink 367
Source/ Comments:
1) DIC, annual report (Apr 2007-Mar 2008); net sales of „Graphic Arts Materials“ only, applied 12 month average exchange rate: 161,61 yen/€
2) Consolidated total net sales
3) Toyo Ink, annual report (Apr 2007-Mar 2008); combined sales of “Printing Inks” and “Graphic arts, machinery and supplies”
sectors only; applied 12 month average exchange rate: 161,61 yen/€
4) Siegwerk brochure „Facts & Figures“
5) Sakata INX, annual report (Apr 2007-Mar 2008); applied 12 month average exchange rate: 161,61 yen/€
6) http://www.inkworldmagazine.com (Sept. 2008)
8 7) http://www.inkworldmagazine.com (Sept. 2008), applied exchange rate: 161,61 yen/€

Flint Group: Locations Worldwide
9
The Executive Management Team
Charles Knott
CEO
Dermot
DermotHealy Bill
BillMiller Dr.
Dr.Dirk
DirkAulbert Dr.
Dr.Thomas
ThomasTelser Craig
CraigFoster Jan
Healy Miller Aulbert Telser Foster JanPaul
Paul
President President President President President van
President President President President President vander
derVelde
Velde
Packaging
Packagingand Flexographic Sr.
and Flexographic Sr.Vice
VicePresident
President
Print
PrintMedia
MediaEurope
Europe Americas
Americas Narrow
NarrowWebWeb Products
Products Pigments
Pigments Procurement
Procurement
10
Company Profile
► 2008 sales: €2.4 billion (US$ 3.5 billion)

► No. of employees: 7 800
► >140 facilities in over 40 countries
► Global network of partners and distributors
11
Flint Group – Strategic Direction
At Flint Group
our Mission is Customers Employees Integrity Continuous
Improvement
Leadership
Teamwork
to become the best performing supplier

to the printing and packaging industries
as measured by our customers, shareholders,
and employees
through our ability to deliver exceptional value,
consistent quality and continuous innovation to
customers around the world.
12
Packaging & Narrow Web
Combined - a global approach
Organisation Packaging and Narrow Web
Dirk Aulbert
President
Packaging &
Narrow Web
Michael
MichaelFien
Fien
Finance
FinanceDirector
Director
Packaging
Packaging&&
Narrow
NarrowWeb
Web
Dirk
DirkAulbert
Aulbert Doug
DougAldred
Aldred
Eva
EvaFreudenthaler
Freudenthaler Dave
DaveHiserodt
Hiserodt Susan
SusanKuchta
Kuchta Matias
MatiasKatila
Katila George
GeorgeLyle
Lyle
Operations
Operations Vice
VicePresident
President
Vice
VicePresident
President Vice
VicePresident
President Vice
VicePresident
President General
GeneralManager
Manager General
GeneralManager
Manager
Packaging
Packaging&& Sales,
Sales,Packaging
Packaging
Marketing
Marketing&& BM
BMNarrow
NarrowWeb
Web BM
BMPackaging
PackagingInks
Inks Narrow
NarrowWeb
Web Narrow
NarrowWeb
Web
Narrow
NarrowWeb
Web &&Narrow
NarrowWeb
Web
Technology
Technology North
NorthAmerica
America North
NorthAmerica
America Latin
LatinAmerica
America Asia
Asia
Europe
Europe Europe
Europe
BM = Business Management
14
Packaging & Narrow Web – Our offer
We offer a complete range for all applications,
including:
► Flexography
High quality solvent and water based Flexo Inks for everything you need
in Packaging Applications
Dedicated press stable water based Flexo Inks for Narrow Web
Low viscous excellent printable UV Flexo Inks for Narrow Web
applications
► Gravure
Wide product range in solvent based and water based for Gravure
packaging printing
► Letterpress, Screen and Offset
Tailor made UV Inks for a wide range of Label Applications in Letterpress,
Screen and Offset
15
Segments we serve:
► Narrow Web Labels

► Flexible Packaging
► Paper & Board
► Aseptic
► Tobacco
► Special Applications
16
Packaging & Narrow Web Sites Worldwide
Europe / Middle East / Africa
Lodz, Poland Liverpool, England

Warszaw, Poland Ruabon, England
United States / Canada Glasgow, Scotland
Stuttgart, Germany
Charlotte Atlanta Willstätt, Germany Dublin, Ireland
Cincinnati Portland Dubai, Middle East Dijon, France
Dixon Vancouver Jo’burg, South Africa Burgdorf, Switzerland
Garland Los Angeles Cape Town, South Africa Vilanova, Spain
Levittown Denver Durban, South Africa Milan, Italy
Neenah Dallas Deventer, Netherlands
Santa Fe Kansas City Trelleborg, Sweden Brøndby, Denmark
Springs Winnipeg Helsinki, Finland Asia - Pacific
Clermont, France
Plymouth Moscow, Russia
Minnesota Chicago Cinisello, Italy Dalian, China
Neenah Winschoten, Netherlands Istanbul, Turkey
Shanghai, China
Toronto
Guangzhou, China
Montreal
Anniston Bangkok, Thailand
Rochester
Kuala Lumpur, Malaysia
Lebanon Lionville
Singapore, Singapore
Columbia
Wingfield, Australia
Greensboro
Geebung, Australia
Plymouth
Ingleburn, Australia
Penrose, New Zealand
Christchurch, New Zealand
Latin America Wellington, New Zealand
Curitiba, Brazil
Dandenong South, Australia
Sao Paulo, Brazil
Bangalore, India
Santiago de Chile, Chile
Bogota, Colombia
San Jose, Costa Rica
Santa Domingo, Rep.Dom
Guayaquil, Ecuador
Lima, Peru
Mother plant
Puerto Principe, Trinidad
Buenos Aires, Argentina Satellite facility
17
Mexico City, Mexico
Narrow Web Market Shares - Global
► Flint Group is a strong number 1
Flint Group
Others
Siegwerk
SUN
EIC
18 2008 data
Narrow Web Market Shares – North America
► Flint Group shares a number 1 position
Others Flint Group
SUN
Siegwerk EIC
Water Ink
Technology
19 2008 data
Narrow Web Market Shares – Europe
► Flint Group is a strong number 1
Others
Flint Group
SUN
Zeller Gmelin
Siegwerk
20 2008 data
Narrow Web Labels
► Including
UV Flexo
Water based Flexo
UV Rotary Screen
UV Letterpress
UV Offset
► Typical end products
Pressure-sensitive labels, cut &
stack labels, in mould labels,
resistant labels, thermal labels,
pharmaceutical labels,
cosmetic labels
21
Food Contact
European Situation
22
A First Definition
► Regulation
“Immediately” in law in all Member States
► Directive
Has to be legislated in each Member State separately
• They can get stricter if they want
23
Food Packaging Issues
►Concentration on inks and coatings designed to

be printed or applied to the non-food-contact side
of packaging
Most affected area
Set-off migration
Ink
Substrate Through migration

Food contact
surface Food
24
Food Packaging Issues
► Intentional Direct Food Contact inks and coatings

Separate requirements
Relatively few manufacturers involved
Major sector is can market
• Food
• Beverages
Flint Group will not supply coloured coatings (inks) for direct food
contact
• We do supply colourless coatings
– e.g. Heatseal for yoghurt lidding
25
Rules & Regulations
► European and National Law

► Self Regulation
► Customer requirement
► Brand Owner/End User requirements
26
Community Legislation
(EC) No 1935/2004 Reference:
Figure 1: Overview of Community Legislation Framework References of European and National
Legislations –
(Last update 25/06.2008 (EC) No 2023/2006
European Commission Working Document
Good Manufacturing Practice
(Applicable to all food contact materials)
Plastic Materials
2007/42/EC 84/500/EEC Elastomers
Regenerated Ceramics & Rubbers
Cellulose Films 93/11/EEC
Nitrosamines
2002/72/EC (EC) No 372/2007 (EC) No282/2008 (EC) No1895/2005

2005/31/EC Monomers Transitional migration Recycled Plastics BADGE/BFDGE
1st Amendment Additives 78/142/EEC limits for plasticizers 82/711/EEC 85/572/EC /NDGE
Vinyl Chloride in Gaskets in lids Migration Testing List of Simulants
2004/1/EC
1st Amendment
93/8/EEC
80/766/EEC (EC) No 597/2008 1st Amendment
VC in PVC 1st Amendment
2004/19/EC Analysis
2ndAmendment
97/47/EEC
2ndAmendment
2005/79/EC 81/432/EEC
3rd Amendment VC in
food analysis
2007/19/EC
4th Amendment
2008/39/EC
5th Amendment
975/2009
6th Amendment
Active &
Paper & Metals & Ion Exchange Varnishes
Glass Intelligent Wood Cork Textiles Adhesives Printing Inks Silicones Waxes
Board Alloys Resins and Coatings
Materials
27
European and National Law
► A “selection of the most important”!

Relevant to food packaging
► REGULATION (EC) No 1935/2004 OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL
on materials and articles intended to come into contact with food
► COMMISSION DIRECTIVE 2002/72/EC
relating to plastic materials and articles intended to come into
contact with foodstuffs
• 2008/59 5th Amendment
► COMMISSION REGULATION (EC) No 2023/2006
on good manufacturing practice for materials and articles intended
to come into contact with food
► Bundesinstitut für Risikobewertung
► Ordinance of the FDHA on Materials and Articles (817.023.21)
Switzerland
28
What does this mean to us?
► 1935/2004 Article 3
General requirements
• 1. Materials and articles, including active and intelligent materials and
articles, shall be manufactured in compliance with good manufacturing
practice so that, under normal or foreseeable conditions of use, they
do not transfer their constituents to food in quantities which could:
• (a) endanger human health;
– or
• (b) bring about an unacceptable change in the composition of the food;
– or
• (c) bring about a deterioration in the organoleptic characteristics
thereof
29
Traceability
► 1935/2004 also demands

Ability to take a piece of print
Trace back to batch of ink, solvent used
And pigments and resins (and intermediates) batches involved
► It is possible – but a major paper chase!!
30
► 2023/2006
In force August 1 2008
Demands that all members of Food Packaging Chain have a
• Good Manufacturing Practice
– Follow it
» Demonstrate compliance
– Including imported articles
Every member has responsibility
• No member can assume responsibility of another actor in chain
Annex
• Relating to inks
– Their application not to infringe Article 3 of 1935/2004
» Must be formulated in such a way as to allow this to occur
: when correctly applied
31
► 2002/72
Introduces substances with limits (SML etc.)
• Effectively direct food contact
– Substances in inks
» Need to supply information to allow “adding up” of “common”
substances
– Colorants & Solvents Excluded
Being replaced by Plastics Implementation Measure
• Due to come into force July 2010
32
Other regulations
► F&DA
Does not apply in Europe
Primarily for intentional direct food contact
Effectively no colourants
One of the criteria of EuPIA selection of Raw Materials
► Inks Resolution – AP (2005) 2
Adopted by Council of Europe
Not ratified in any Member State
Not supported by EuPIA
If it were adopted
• 80 % of Food packaging cannot be printed
33
Self Regulation
► Most European ink-makers are members of EuPIA

► By being member following are guaranteed
Obey Exclusion List
• CMR and Toxic materials banned from use
• Some others
– e.g. Heavy metals
Follow Guideline when formulating inks for use on food packaging
Follow GMP when manufacturing inks for use on food packaging
• Documented
• This gives traceability demanded by 1935/2004
– Ink modification on press needs to be recorded
To demonstrate compliance in ink store
34
Current Disclosure
► Statement of Composition
Sets out materials used in Plastics Directive – with a limit
• % in dry ink film is declared
– To allow “totting-up” with other sources of same material
Dual Use substances
Other as separate disclosure
Model Document
► Further information
Potential migrants
• <1000 Daltons
• With relevant information
– CAS, PM, SML etc
– Worst Case Calculation where possible
Template
35
Statement of Composition
36
Disclosure Template
Potential Migratable Components Disclosure
Strictly Confidential
Potential Migratable Components of Product

Applied
Dry
% in ink Weight
supplied to
Dry Weight Listing exceed Basis for Dual
Product name PM Ref. CAS No. Name (A) (1) Restriction limit (2) Safety (3) Use? Comments (4)
Notes:
(A) Percentage of component in ink/coating - expressed as percentage of solids of dry ink
(1) For example:
Plastics Directive (PD)
Synoptic Document (SD) with SCF List number
(2) Worst case calculation used to show the applied dry weight of ink or coating which would mean that the specified component would exceed the restriction level.
This is based on product weight in previous column, 100 % coverage (in case of inks etc), 6
(3) Basis for safe use can include:

Worst case calculation (WCC)
Testing on level in product (Test)
Practical Global Migration tests (Gmig)
Practical Specific Migration tests (SMig)
Migration modelling (MM)
(4) To include references to migration test reports etc
37
Disclosure Example
Potential Migratable Components Disclosure
Strictly Confidential
Potential Migratable Components of Product

Applied
Dry
% in ink Weight
supplied to
Dry Weight Listing exceed Basis for Dual
Product name PM Ref. CAS No. Name (A) (1) Restriction limit (2) Safety (3) Use? Comments (4)
XXNN-NNNX Acetyl Tributyl OML
93760 77-90-7 Citrate 8.7 PD (60mg/kg) 11.5 WCC No
OML
52720 1121-84-5 Erucamide 2.9 PD (60mg/kg) 34.5 WCC Yes
Notes:
(A) Percentage of component in ink/coating - expressed as percentage of solids of dry ink
(1) For example:
Plastics Directive (PD)
Synoptic Document (SD) with SCF List number
(2) Worst case calculation used to show the applied dry weight of ink or coating which would mean that the specified component would exceed the restriction level.
This is based on product weight in previous column, 100 % coverage (in case of inks etc), 6
(3) Basis for safe use can include:

Worst case calculation (WCC)
Testing on level in product (Test)
Practical Global Migration tests (Gmig)
Practical Specific Migration tests (SMig)
Migration modelling (MM)
(4) To include references to migration test reports etc
38
Some Current Issues
39
EuPIA Public Inventory List
► Initial List – partial

• Published May 2008
• Updated November 2008 & June 2009
Colorants
Solvents & acrylate monomers
Photo-initiators
► Resins and Additives
Had to be broken back to starting substances (monomers)
• By Raw Material Suppliers
• Information fed into Database On Line
– Suppliers Database on Food Contact Materials
List complete as of end September 2009
► Submitted to Swiss Authorities
Publication early 2010
In law April 1st 2010
40
Swiss Ordinance – 817.023.21
► This was based on the EuPIA Inventory List so should

match most of it
There are some differences in between the part A (evaluated) and
non-evaluated
• To be discussed with BAG
Could be some problems with solvents
Will be the basis of the new Nestlé specifications
• And other Brand Owners
De facto EU legislation
• Some Member States will take into their own laws
– We hope there will be harmonisation
Applies to all inks for food packaging
• W/B, S/B, UV
41
Swiss List
► A European List
► Some End Users thinking of making it Global
Not feasible
42
Sheetfed Litho inks
► Much of the problem is due to lack of legislation on

paper and board
Means everyone has to interpret requirements
• Causes uncertainty
For plastics – PD gives ground rules
► Low migration systems available
Cost implications
► Industry Task Force identified in 2008 that unsuitable
inks being used for Food Packaging work
EuPIA Information Note published February 2009
43
EuPIA Information Note on Sheetfed inks
44
Low Migration Systems
► Solvent Based
Direct film packaging
• No real issues
• Flint Group major supplier
► Waterbased
Again no major issue
• Can be a lot of minor components which may be potential migrants
• Amines present in ink above SML
– Should evaporate/react with paper
– Needs confirming by testing
» Has been done several times and never a problem so far
45
Low Migration Systems
► Litho
Nestlé approved
• Novasens Premium
• Ultraking 7000 XLM
► Narrow Web
Flexocure Gemini
• Should meet specifications
– When tested in final application
• Other systems will also comply
– Some application dependency
Low migration system in Development
46
Primary Food Packaging
► February 2009 4-MBP found in Cereal

► Board was printed as secondary packaging
Inner bag
► EFSA opinion (updated May 2009)
No health risk
SML for Benzophenone increased
► Definition of Primary Food Pack needed
47
European Parliament and Council Directive 94/62/EC of
20 December 1994 on packaging and packaging waste
► Article 3
Definitions
'packaging` shall mean all products made of any materials of any
nature to be used for the containment,protection, handling,
delivery and presentation of goods,
• a) sales packaging or primary packaging,
– i. e. packaging conceived so as to constitute a sales unit to the
final user or consumer at the point of purchase;
• b) grouped packaging or secondary packaging,
– i. e. packaging conceived so as to constitute at the point of
purchase a grouping of a certain number of sales units whether
the latter is sold as such to the final user or consumer
• c) transport packaging or tertiary packaging
► On this basis
Primary packaging not just direct food contact
• Some conflict with 1935/2004
48
Self Adhesive Labels on Food Packaging
► Effectively in Scope
49
Migration
► Use a barrier
Absolute Barrier
• Metal Can
• Glass Bottle
Functional Barrier
• Defined also as 9µ Al Foil
► Therefore
Not possible in most packaging to be sure that barrier is present
• Multi-layer structures may act as “Effective Functional Barrier”
• Must test in the final form
– This is true for all packaging
» Even if “Low Migration” ink being used
Certainly no coatings are barrier
• Even if there were some would need to be double applied
– To ensure no pinholes
50
Low Migration Ink - definition
► Proposed by EuPIA
► A "low migration ink" designed for use on food packaging is
formulated using selected components which should ensure that
migration from the resultant printing ink film will be within
accepted migration
provided that the packaging structure is suitable, and the packaging ink is
applied under Good Manufacturing Practices in accordance with
guidance given by the ink supplier for the intended application
► This should be supported by indicative analytical testing and/or
relevant worst case calculations.
► As a result – assuming correct application and appropriate
packaging type – any migration from the printed packaging
should be within currently accepted limits.
51
Migration assessment
► From Statement of Composition

Assess risk of migration
If considered necessary check for migration
• Must be on final commercial print
► If pack is multi-layer
Who tests?
Ultimate responsibility is “person placing pack on market”
• Who is this?
52
What to use where?
Is the inner wrap a Wrap to Is the outer Possible vapour Ink Examples
Case barrier to ink be printed wrap a barrier to phase transfer or Recommendat
ingredients? ink ingredients? set-off ion
No Inner Not relevant Not relevant Low migration single wrap packaging, e.g.
1 - printed paper bag or cardboard box, also PE
coated ones, or
- printed flexible pouch or rigid container made of
non-barrier material (e.g. PP or PE), or
- plastic bottle with printed label
53
What to use where?
coated ones, or
No Outer No Not relevant Low migration - cereals in PP pouch in a printed cardboard box
2
54
What to use where?
coated ones, or
2
No Outer Yes Yes Low migration - printed box made of aluminium laminated board,
3 containing sweets wrapped in paper or PP
55
What to use where?
coated ones, or
2
No Outer Yes No Standard

4
56
What to use where?
coated ones, or
2

4
Yes Inner Not relevant Yes Low migration - aluminium lidding for yogurt, or
5 - printed pouch made of barrier laminate material,
or
- coated/printed cans where set-off is possible, e.g.
with internal lacquer, or
- packaging made of laminate material with
aluminium as inner layer
57
What to use where?
coated ones, or
2

4
or
Yes Inner Not relevant No Standard - glass bottle or can with printed label, or
6 - coated/printed cans where set-off can be
excluded, e.g. without internal lacquer
58
What to use where?
coated ones, or
2

4
or
Yes Inner Not relevant No Standard - glass bottle or can with printed label, or
6 - coated/printed cans where set-off can be
excluded, e.g. without internal lacquer
Yes Outer Not relevant Not relevant Standard - glass bottle in printed outer container
7
EuPIA
59 proposed document – to be ratified by Packaging Chain
Summary
► Through use of
GMP
Statement of Composition
Other disclosures
► Ink-maker can supply full support to Packaging Chain
to allow evaluation and confirmation of conformance
to:
GMP – 2023/2006
Framework Regulation – 1935/2004
► Ensuring maximum consumer safety
► This is not the end of the line
► Continued Improvement – pro-active – is a basic
concept of the industry.
60
REACH
61
Importers – EU Customs territory
EU 27 MS (some territorial exceptions)

French overseas territories – Reunion, Martinique,
French Guyana
Channel Islands, Isle of Man
EFTA adopted REACH by 1.6.08
EEA countries: Norway, Iceland, Liechtenstein in
Non-EEA countries: Switzerland out
Anything coming from Swiss supplier is imported
62
Definitions
An article is the term for any object that has been given a specific shape, surface or design
which determines its function to a greater degree than does its chemical composition (e.g.
manufactured goods such as textiles, electronic chips, furniture, books, toys, kitchen
equipment).
ECHA – Guidance for Identification and naming of substances under REACH
63
Who is a Downstream User?
Manufacturer / Importer
Downstream users
Formulator 1 Ink-Maker Formulator 3
Industrial user
1) Use as a processing aid Professional user
2) incorporation into articles
Distributor Consumer
64
Who is a Downstream User?
Manufacturer / Importer
Downstream users
Formulator 2
Formulator 1 Formulator 3
Ink-maker
Printer/Converter
Professional user
Distributor Consumer
65
Timeline of REACH implementation
Phase-in substances registration

Agency start-up
Pre-registration
>1000tonnes
CMR 1, 2 > 1 t
R50/53 > 100t
100-1000 tonnes 1-100 tonnes
Registration of non Phase-in Substances
31 May 2018
1 Dec 2008 30 Nov 2010 31 May 2013
1June 2007
1 June 2008
66
Current situation
► Majority of substances pre-registered by suppliers

Based on statements/promises from suppliers
► Imported materials
Ink-makers doing some pre-registration
► Anticipate little disruption/reformulation
Before 2010, and probably 2013
Some alternative pigments/resins “known equivalents” may happen
• Cost implications
► Substances of Very High Concern
Initial list of 15 published October 28 2008
Second list published January 2010
• As far as known not an issue to most ink-makers
• Future updates will need to be watched
Obligations on suppliers of Articles
• From 28 October 2008, EU & EEA suppliers of articles which contain substances
on the Candidate List in a concentration above 0.1% (w/w) must provide sufficient
information, available to them, to their customers and on request to a
consumer within 45 days of the receipt of this request. This information must
ensure safe use of the article and, as a minimum, include the name of the substance.
67
Descriptors of Use
► For practical purposes

under REACH, “use” is
Handling.
68
Use Descriptors
Element Code Purpose Examples

Indicator of where the substance is used or SU3 Industrial Manufacture (general)
Sector of Use SU type of user: industrial, professional, consumer
SU 10 Chemical Formulation/repacking
SU 21 Consumer Use
Indicator of how substance is handled (human PROC 2 – used in closed systems with
Process PROC exposure) occasional controlled exposure
PROC 10 Roller coating (printing)
Category
Indicator of the type of the product in which PC 9 Coatings
Product PC the substance is used PC18 Inks
Category
Indicator of the type of article in which the AC 7-2 Metal Products; Toys
Article AC substance is used Not needed in application report
-with no intended release
Category -- with intended release
Indicator of how the substance may be ERC 2 formulation

Environmental ERC released to the environment ERC 3 production of articles
Release ERC 4 VOC’s
ERC 5 Solids
Category
69
What is an Article?
“2.7 Packaging and containers
Substances, preparations and

articles can be contained inside
of packaging. This packaging,
be it a carton, a plastic wrapping
or a tin can is considered as
article under REACH.
Normally there is no intended

release from packaging
materials.”
70
Articles
► Printers and suppliers of print into Europe

► Supply Articles
► Therefore no issues
Unless there are SVHC’s above 0.1%
71
Be Grateful
► You are not heavily involved

Communication and feedback in the supply chain
The workflow recommends communication through the complete supply chain to take
place at two stages during the ES development process:
Communication of uses, according to the Use Descriptor and ERC system, which
are intended to be covered by the M/I will take place at an early stage in the
Registration process. This is to provide an opportunity for DUs to determine whether
their uses are covered by the M/I and if not, to communicate their use to the M/I. The
uses will be communicated by a description of (provisional) Use title and Use
Descriptors and ERCs according to the Technical Guidance Document (ECHA:
Information Requirements and Chemical Safety Assessment, part R12 (Use Descriptor
System)[1]). Please note that this document is currently being updated. The updated
version will be available in the coming months.
Communication of the ESs intended to be published through eSDSs; this will take
place at the stage of finalizing the CSA/CSR for submission to the ECHA.
Communication at this stage allows the DU to evaluate his situation versus the OCs
and the RMMs described in the provided ES.
72
Carbon Footprint & Sustainability
73
Carbon Footprint as part of Sustainability
► Carbon Footprint is only one aspect of Ink as a part of the

Environment
► Flint Group has a policy of operating sustainability in terms of
“The Three Pillars”
• Environmental Protection
• Social Equity
• Economic prosperity
In Specific Areas
• Raw Materials
– Maximising those from renewable sources
– Optimising the use from non-renewable sources
• Energy
– Minimising the Energy demands in manufacture
» Continuous Improvement Process
• Employees
74
The Buzzwords
► Green
What is “green?”
• Water vs.solvent vs.UV
► Sustainable
► Global Warming
► Carbon Footprint
► Environmentally Friendly
Water-based inks are better for this ?
75
Is there one Answer?
► No
► It is a case by case basis
Water can be “greener” than solvent
Water can be “less green” than solvent
► Define “Green”
► It is the total concept we need to look at
76
They all start in the same place
77
Application
► Water needs to be dried

Non-absorbent substrates
• This is more energy demanding than solvent
Does not apply to paper and board
• Or does it?
– Light weight papers will cockle without drying
– Possible set-off onto back of paper
For heavy duty corrugated
• No argument – water is better
► Solvent prints faster
By law there is emission control
Little solvent gets into the atmosphere from the presses
► UV energy drying tends to be cheapest
► Water is “easier” to recover
Have to be quite clever – not just settling tanks
• Purification needed
Waste solvent can be distilled off
• Re-use for cleaning/as a fuel source
78
The ink - technically
► Water is a poor solvent for pigments and resins

► Water-based inks often more matt & higher pigmented
for same strength
Need more energy to achieve same result on print
► Water is safer to handle – insurance and other
benefits
► UV also non-flammable
► None of the liquid inks print well wet on wet
New UV press and inks which are reported to give good results
UV wet on wet is standard and can compete on most substrates
► UV sharpest print
Water worst
79
Recyclability of paper – de-inking
► Solvent is the easiest
80
Sustainability
► Many definitions of sustainable

► Are the products from renewable resources?
Generally no
• Ethanol can come from bio-sources
– In competition with fuel
• There are vegetable based litho inks
– Often a Genetically Modified issue
► Ink-makers look to:
Maximise efficiency of production
• Minimises energy demands
– Minimises impact on global warming
• Maximises life of available materials
• Investigate new materials as they are developed
In order to provide an on-going environment for our children
81
Renewable Raw Materials
► Solvent Based Inks

Nitrocellulose
• Base component comes from trees
Rosin based modifying resins
• Trees
• In Europe – source of fuel preferred by legislators
Additives
• Fatty Acid Amides
Solvent
• Bio-ethanol
82
Greenhouse Gas Emissions
Global
49
Billion
tonnes
Europe
4.2 bn Tonnes
83
GHG EMISSIONS EXAMPLE: EUROPE
GHG Emissions Europe per sector:
Solvent Use
0.19%
Industry
7.60% Ink use = 0.004 %
Agriculture
9.20%
21%
Energy
60%
Quelle: EEA Report 2006 / * Schätzung
EuPIA = European Printing Ink Association (based on annual production volume)

84
Carbon Footprint
► The Carbon footprint of the inks generally contribute

to less than 1% of the product
Package, newspaper etc.
► For food packaging carbon footprint of waste food
due to poor labelling/packaging/information many
times greater than the package
► Not something to be forgotten
Take it in context
85
Carbon Footprint
► Carbon Footprint
EuPIA (DE) figure of 0.495 kWh/kg
• Production of inks
– Average
Therefore the Carbon Footprint for the same
• Varies from country to country
• Dependent on source of electricity
– Sweden 1 kWh = 44 gms CO2
– Greece 1 kWh = 814 gms CO2
– Other countries in between
» France = 84 gms CO2
» Germany = 500 gms CO2 (wide variation)
» UK = 430 gms CO2
Transport
• Truck
– 4.1 gms CO2 per 100 kms
86
Carbon Footprint (cont.)
► Raw Materials
Pigments and Resins
• Manufacture per kilo similar to the ink manufacture
– Make up 25-40% of ink
► Raw Material Transport
All bulk shipped, therefore transport impact per kilo minimal
87
FACTS: CARBON FOOTPRINT – Potato Chips
Raw Materials
Manufacturing
► 75 g CO2
per package
Packaging
Ink contribution:
Transportation
0.01%*
(*estimate)
Package Disposal
Source: Carbon Trust

88
Carbon foot print – Fat Tire Amber Ale
Use (consumer 6-Pack = 3.2 kgs of CO2

refrigeration)
8%
Retail (mostly
Other
refrigeration)
7%
28%
Distribution
(trucking)
8%
Brewery
Operations
4%
Malt
6%
Paper (Carton
and Label &
Ink)
2%
Barley
Glass
13%
22%
Added carbon
dioxide
2%
89
Source: Wall Street Journal; New Belgium Brewing Co.
Carbon Footprint - Magazine
► Ink included inside Material section

Major component is paper
Production CO2 Equivalent

2%
1%
7%
1%
2%
Energy
Materials
15% Transport
Staff Transport
Packaging
58% In-house-Waste
Amortisation
14% External waste
90 Source:Group Prisma Presse

Environmental Impact
► Look at the whole chain

Inks
Printing
Waste & recovery
The final product
Protection benefit vs no protection and environmental impact
► Then make your mind up
91
Summary
► The environmental impact of unprinted far outweighs

the impact of ink-making and application
Western Europe 3% of Food Spoils before reaching customer*
Developing Countries = 50%*
Rotting food develops high levels of GHG
► But
We must not be complacent
We must reduce it further
• TOGETHER
92 * Packaging in the Sustainability Agenda – Europen & ECR Europe

Thank you for your attention
chris.whitehead@eu.flintgrp.com
93

Printing Inks - Issues, Guidance and Regulations

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Printing Inks – issues,

guidance and regulations

► Flint Group Overview

► Inks for all types of substrates and applications

► Lithographic printing blankets and sleeves

► Integration of these two businesses created XSYS Print Solutions,

► Integration of these businesses lead to creation of Flint Group,

► May 2007 Flint Group acquired Day International, a leading supplier

Net Sales 2007

3 Toyo Ink 878

6 Huber Group 750

Chris Whitehead – February 2010

► 2008 sales: €2.4 billion (US$ 3.5 billion)

to become the best performing supplier

► Narrow Web Labels

Lodz, Poland Liverpool, England

► Flint Group is a strong number 1

► Flint Group shares a number 1 position

Others Flint Group

► Flint Group is a strong number 1

►Concentration on inks and coatings designed to

Substrate Through migration

► Intentional Direct Food Contact inks and coatings

► European and National Law

2002/72/EC (EC) No 372/2007 (EC) No282/2008 (EC) No1895/2005

► A “selection of the most important”!

► 1935/2004 also demands

► Most European ink-makers are members of EuPIA

Potential Migratable Components of Product

(3) Basis for safe use can include:

(4) To include references to migration test reports etc

Potential Migratable Components of Product

(3) Basis for safe use can include:

(4) To include references to migration test reports etc

► Initial List – partial

► This was based on the EuPIA Inventory List so should

► Much of the problem is due to lack of legislation on

► February 2009 4-MBP found in Cereal

► From Statement of Composition

No Outer Yes No Standard

No Outer Yes No Standard

No Outer Yes No Standard

No Outer Yes No Standard

EU 27 MS (some territorial exceptions)

Formulator 1 Ink-Maker Formulator 3

Phase-in substances registration

Registration of non Phase-in Substances

► Majority of substances pre-registered by suppliers

► For practical purposes

Element Code Purpose Examples

Indicator of how the substance may be ERC 2 formulation

“2.7 Packaging and containers

Substances, preparations and

Normally there is no intended

► Printers and suppliers of print into Europe

► You are not heavily involved

► Carbon Footprint is only one aspect of Ink as a part of the

► Water needs to be dried

► Water is a poor solvent for pigments and resins

► Solvent is the easiest

► Many definitions of sustainable

► Solvent Based Inks