The Swiss Packaging Institute (SVI), together with its specialist group JIG (Joint Industry Group for Packaging Safety), has published a new guideline on the interpretation of the revised Swiss Ordinance on Printing Inks. The document is intended to support companies along the packaging value chain in implementing the verification obligations that will apply from February 2026.
When the revised Ordinance 817.023.21 comes into force on 1 February 2026, the requirements for printing inks in food contact materials will become significantly stricter. Article 35a in particular introduces a comprehensive obligation to provide a Declaration of Compliance (DoC) for printing inks, printed layers and materials used. The guideline coordinated by the SVI is intended as a practical interpretation aid to implement the legal requirements in a standardised and comprehensible manner.
Practical design aid from the industry
The guideline was developed within the SVI JIG specialist group with the involvement of the Swiss Food Safety Ordinance (FSVO) and representatives from industry and the value chain. It is not legally binding, but is intended to help avoid misinterpretations of the ordinance and facilitate the practical application of the requirements in Annex 15 in particular.
The central aim is to harmonise the flow of information between printing ink manufacturers, converters and the food industry. Standardised Statements of Compliance (SoC) from printing ink manufacturers to converters and Declarations of Compliance from converters to downstream stages are envisaged. The guideline also makes it clear that the revision of the regulation does not shift the fundamental responsibilities within the supply chain.
Clarification of substance definitions and risk assessment
The guideline also focuses on the interpretation of substance categories. It distinguishes between intentionally added substances (IAS), non-intentionally added substances (NIAS) and CMR substances. For NIAS, risk-based assessment approaches according to EFSA guidelines are described, including the requirements for toxicological assessments and acceptable migration limits.
CMR substances must not be used intentionally. If they occur as NIAS, a well-founded risk assessment is required. The guideline describes both regulatory test pathways and the use of read-across approaches, in silico models and expert judgement if no harmonised classifications are available.
Increased demands on converters and testing strategies
The responsibility of converters is explicitly emphasised in the guideline. They must check the information provided by ink manufacturers and ensure that the underlying modelling assumptions, worst-case calculations and test conditions are suitable for the end application in question. In addition, NIAS that arise during the printing or finishing process or originate from other packaging components must be assessed.
With regard to migration tests, the guideline points out that there are no harmonised test conditions for paper and board applications. An unreflected transfer of test parameters from the Plastics Regulation (EU) No. 10/2011 is not recommended. Instead, the SVI advises early coordination of suitable test conditions between all parties involved.
Guidance for implementation
With the publication of the guideline, the SVI, together with the JIG specialist group, is providing a central working tool for the industry. The aim is to implement the new legal requirements consistently and, at the same time, to identify practical solutions for dealing with NIAS, migration tests and documentation obligations. For manufacturers, converters and brand owners, the document thus offers important guidance for preparing for the regulations that will apply from 2026.
Source: SVI
