Legislation and education are key

15 April 2014



In conversation with FINAT, Converting Today discussed the latest developments in the labelling market with managing director Jules Lejeune and public affairs manager Mark Macaré.


In a European market for labels measured at 5.97 billion m², 45% is represented by pressure sensitive, according to FINAT, the European association for the self-adhesive label industry. Worldwide, wet glue and pressure sensitive are equal at about 39% each of a market that is just over 50 billion m². At 29%, Europe is the second largest market by volume (just behind Asia Pacific at 36%).

In terms of labelstock, in Europe the top five self-adhesive label consuming countries account for 60% of all demand, with Germany
and Italy leading consumption, followed by the UK, France and Spain. FINAT figures show demand is growing at about 1.5-2% per
year (down from a high of 5% year on year 2010-2011) and film materials have a slightly higher growth than paper, but they are now
almost on par.

In terms of opportunities, the greatest potential remains in Eastern Europe, which continues to see the largest growth at approximately 11.4%.

Looking beyond the horizon
Jules Lejeune:
FINAT as an association is not launching products or innovations in the sense of product decoration or identification
itself, but offers products and services to its members to encourage the development and marketing of new products and applications.
In fact, our vision for the medium term is to be the internationally recognised source of knowledge, networks and information strategic to the success of label businesses.

Our association offers a top level meeting point for business executives on a European level. The issues we address are focused on the longer term development of self-adhesive and adjacent product decoration and product identification technologies. By connecting the entire value chain and all disciplines, FINAT helps the industry to keep an open eye to trends and developments that will impact the future business development.

Information is available all over the internet nowadays, but the strength of the FINAT network is that different areas of expertise
represented in our membership meet and interact. As the independent label industry platform, FINAT acts as the invisible force of
new product development and innovation. It is the role of an international umbrella association like FINAT to look beyond the immediate business horizon of its members and bring items to the table that pull them 'out of the box'.

Legislation matters

Mark Macare: Following the entry into force of the European Commission Plastics Directive, we are closely following the development of the German Ordinance for printing inks and varnishes, where we are anticipating a final version. This Ordinance is to contain a positive list for permitted substances, together with migration limits, and would require close communication throughout the supply chain to ensure compliance. While it would require closer communication and co-ordination in the supply chain, the Ordinance and the positive list would be a step forward in the reduction of uncertainty and in the assurance of food packaging safety.

One other point of interest on the horizon is the upcoming revision of the EC BREF STS, Reference Document for Best Available Techniques on Surface Treatment using Organic Solvents. Our current understanding is that a kick-off meeting for this would take place at the end of this year or early 2015, and it will be essential to co-ordinate industry input for this process.

The Biocidal Product Regulation is a final area of interest, with the status of treated articles being a strongly debated topic. After a meeting with the Commission, we understand that this section is to be updated shortly, to incorporate input from the industry and hopefully to iron out some of the wrinkles that existed.

Survival comes down to more than price competitiveness: failure to comply with legislation positions the label printer not only as an 'also-ran' but as a complete non-starter in the end-user's qualification process.

Plastics Directive

MM: The new EU 10/2011 specifically concerns all plastics materials and articles intended to come into contact with foodstuff,
with labels considered an integral part of such packaging. EU10/2011 consolidates 2002/72/EC and seven amendments (these were previous regulations for plastics).

The idea of the regulation is to harmonise the different legislation that has existed previously within individual member states.
This should make it easier for different countries to deal with each other in terms of the shipping of goods.

Both direct food contact labels furnished with a plastics layer, and plastics labels applied to food packaging, now require Declarations of Conformity (DoCs) stating which controlled but authorised substances are present in their make-up. Only when the
packaging material or any layer provides a functional barrier that prevents migration of substances from behind that barrier into food, are labels and other packaging components exempt from EU 10/2011. Material compositions that are purely combinations of paper and board continue to be covered by national legislation or recommendations such as those of the German BfR.

Restricted and unrestricted substances

MM: All authorised substances - both restricted and unrestricted - that may be used in packaging containing plastics in their layers are stipulated on the Union List within EU 10/2011. Only restricted substances need to be declared; and as DoCs move downstream within the supply/manufacturing chain, such substances must be clearly identified and documented, so that compliance can be optimally tested. Final responsibility for conformance lies with the end-user.

It is the end-user - packager or brand-owner - who has final responsibility for checking that the packaging as a whole conforms to EU 10/2011 (in addition to any extant national legislation for papers, as well as to EC 1935/2004, the Framework regulation for all packaging materials), taking into account the nature of the packaged food, its defined shelf life, and ambient conditions. Label printers are therefore required to provide DoCs for their labels, to enable tests for restricted substance levels and migration behaviour in specific environmental conditions to be carried out.

Label printers: responsibilities and risks

MM: Label printers supplying into the EU therefore need to be provided with DoCs both from their labelstock and ink suppliers, to be able to compile their own DoCs, which must, of course, also incorporate conformance information about any curing processes used
during label production.

It should be noted that the enactment of these regulations means that printers unable to supply DoCs cannot now be accepted as
part of the end-user's supply chain, and may also leave themselves open to the financial repercussions of a product recall. It is
therefore essential for label printers to be proactive in obtaining and supplying the necessary documentation if they are to retain their place as responsible and viable links in the broader professional packaging chain.

The benefits of a secure supply chain

MM: To summarise, all the above points underline the value of DoCs as a form of insurance for a label printer's business, as a means of retaining existing customer contracts, and as an entry ticket to end-users' qualification processes for new business - with the ultimate aim of protecting the consumer. Producing DoCs to a satisfactory standard creates a level playing field for all operations - however large or small.

Education

JL: New technology awareness is an important element of our strategy and we will be setting up a series of webinars or smaller
scale workshops to enable our members to stay up to date on issues such as printed electronics, flexible packaging, augmented
reality, sleeves and even direct print.

It is our belief that in order to understand the drivers and challenges facing our members, it is necessary to look outward and understand neighbouring developments. For this same reason, we have been offering knowledge and information to final users of labels and decoration technology, so as to make them understand the comparative benefits of self-adhesive technology compared with alternatives.

On the other hand, we are continuously making efforts to enter and remain in dialogue with our markets to better understand their requirements.

Although there is little that a European association can do itself in the area of vocational training (this is often a local issue determined by language and local training programmes), there is a role for FINAT in supporting programmes that aim to
harmonise operator curriculums on an international scale and accredit training programmes in accordance with commonly agreed international standards.

www.finat.com



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