Update on the German Printing Ink Regulation:
Based on the latest information and the published draft version of the amendment to the regulation, the deadline for the application of the positive list of the German Printing Inks Ordinance has been extended .
The entry into force of these requirements is expected to be postponed until December 31, 2026. This decision provides additional time for manufacturers and packaging and label producers to prepare for the upcoming requirements.
Please note that this is a draft amendment , therefore the final decisions will be approved after the completion of the legislative process.
Germany has approved new regulations for printing inks and varnishes for food packaging. The basis is a “positive list” of permitted substances, migration limits and extended traceability requirements. Most of the provisions will apply from 1 January 2026.
What specifically is changing?
- Positive list: clearly defined substances that can be used in printing inks and varnishes for food packaging.
- Migration limits: limits are set on how much substances can migrate from dyes into food.
- Traceability and compliance: Suppliers must prepare compliance documents and ensure control of the origin of materials.
- Transition period: most provisions apply from 1 January 2026, so companies have time to adapt.
What impact will this have on the sector?
The change will affect the entire chain: from ink manufacturers and adhesive suppliers to packaging/label manufacturers and food industry customers. It is likely that raw material compositions will need to be reviewed, migration test plans, GMP procedures and supplier declarations of conformity will need to be updated.
The wider EU context
The German move is seen as a precedent for a unified EU regulation of printing inks on food packaging, meaning that requirements could be harmonized across the EU in the coming years.
What to do now? (to-do list)
- Review the composition of the inks/varnishes used - whether the substances are on the permitted list.
- Request compliance documentation and evidence of traceability from suppliers.
- Evaluate the results of migration tests and, if necessary, schedule additional tests.
- Plan to transition to certified products by 2026-01-01.