Legislative Structure
Specific legal proposals in Germany aim to restrict the migration of mineral oil aromatic hydrocarbons from recycled paper packaging into food products. The German draft mineral oil ordinance focuses on the protection of human health by setting a limit for the transfer of these substances. It identifies recycled board as the primary source of the problem due to the presence of old newspaper inks.
This regulation has undergone several revisions since its initial introduction.
Migration Limit
Maximum levels of aromatic hydrocarbons allowed to reach the food are set at very low concentrations. If a package exceeds these limits, it cannot be placed on the German market.
Barrier Requirement
Compliance with the proposed rules often necessitates the use of a functional barrier between the recycled fibre and the food content. This layer can be a coating, a film or a specific treatment that stops the movement of volatile molecules. Testing the effectiveness of these barriers involves long term storage studies or accelerated gas phase migration tests.
Some producers opt for virgin fibre substrates to bypass the need for such barriers entirely. The ordinance emphasizes that the burden of proof rests with the food packer. Industry standards have shifted toward low migration inks as a preventive measure.