As the transition period for Germany’s Printing Ink Ordinance comes to an end, OEMs and their ink partners need to be ready for a more defined regulatory landscape.
From 1 January 2027, the German requirements for printing inks used on food-contact materials will become particularly significant for manufacturers supplying the German market. The legislation establishes a positive list of substances that can be used in printing inks for food-contact materials, alongside specific restrictions and migration requirements. Substances not listed must not be classified as CMR under chemical legislation (CLP Regulation). In addition, migration must not be detectable i.e <10 ppb, detection limit.
For metal decoration, this is an important development.
What does it mean for metal packaging?
Printed metal packaging is often designed so that the ink sits on the exterior of the pack rather than directly against the food. However, that does not mean food-contact considerations can simply be disregarded.
The German requirements distinguish between inks intended to come into direct contact with food and those applied to the non-food-contact side. For non-direct applications, certain non-listed substances may still be permitted subject to conditions, including restrictions relating to CMR classification and migration. The legislation also provides routes through substances listed under the EU Plastics Regulation, subject to the relevant restrictions.
For metal decorators and canmakers, therefore, the focus is not simply on whether an ink is labelled “food compliant”. It is about understanding the complete application, the ink formulation, the substrate, the print process, the packaging structure and the potential for migration.
Compliance starts with the formulation
This is where having the right ink partner becomes increasingly important.
At Fujifilm Ink, regulatory expertise is integrated into our ink development process rather than being treated as a final-stage check. Our R&D, analytical, quality, technical and compliance teams work together to understand changing regulatory requirements and their implications for formulation and manufacturing.
That approach is particularly valuable as regulations evolve. When a raw material comes under scrutiny, the impact isn’t simply a regulatory question. Reformulation can affect curing, adhesion, flexibility, printability, appearance, retort or pasteurisation performance, substrate interaction and long-term stability.
For metal decoration, where the ink must perform reliably through demanding production and end-use conditions, compliance and performance must work together.
A portfolio built for the demands of metal decoration
Our metal decoration ink portfolio has been developed around the demanding requirements of modern can and metal packaging production, with solutions already under reformulation that meet the new standard of German Ink Ordinance.
For UV metal decoration in particular, our approach combines Fujifilm’s long heritage in UV ink technology with the specialist expertise required for metal packaging applications.
Our development philosophy focuses on more than simply achieving regulatory requirements. It is about delivering inks that provide consistent jetting, reliable curing, adhesion, durability and production performance, while supporting the increasingly demanding compliance requirements of FCM, food compliant materials (previously referred to as IDFC).
Our portfolio is developed with requirements including FCM, Nestle, Swiss Ordinance and other relevant industry guidance in mind, alongside ongoing regulatory monitoring. Where specific regulatory claims or market approvals are required, these should always be assessed against the intended application and finished packaging construction.
Why heritage matters
Regulatory change is not new to Fujifilm Ink.
Our experience in digital UV inkjet stretches back to 1999, with our screen ink heritage dating back to 1951, giving us decades of knowledge in formulation, compliance and manufacturing, but additionally due to digital, Fujifilm Ink’s expertise include printhead integration, curing, substrates and industrial applications too.
That heritage becomes particularly valuable when regulations change, because replacing a raw material is rarely as simple as trading one ingredient with another. The formulation needs to be re-engineered, analysed and validated to ensure the resulting ink continues to deliver the performance the printer, OEM and end customer depend upon.
This is where our R&D and Compliance teams working side-by-side become a real advantage.
Regulatory intelligence can feed directly into formulation development. Analytical teams can investigate the chemistry and performance of new formulations. Technical teams can validate application performance. Quality teams ensure consistency through manufacture. And our manufacturing expertise allows solutions to be scaled and reproduced reliably.
Compliance isn’t something we add to the ink. It is part of how we engineer it.
Preparing for 2027 — and beyond
The end of the German transition period should be viewed not simply as a regulatory deadline, but as an opportunity for manufacturers and OEMs to review their ink supply chains, are ask some questions.
Which raw materials are critical?
How resilient is the formulation?
How quickly can an ink partner respond to regulatory change?
What technical and analytical resources sit behind the product?
And perhaps most importantly:
Can your ink partner support you for the lifetime of your application, rather than simply supply the ink you need today?
At Fujifilm Ink, we believe long-term reliability comes from combining ink chemistry, regulatory expertise, analytical capability, manufacturing excellence and application knowledge.
For our metal packaging partners, that means developing solutions designed not only to perform today, but to provide confidence as regulatory expectations continue to evolve.
Because the future of FCM demands more than compliant ink, it demands an ink partner prepared for what comes next.
Fujifilm Ink — We know UV!