The European Printing Ink Association (EuPIA) has published the completely revised 5th version of its Good Manufacturing Practice (GMP) for Printing Inks used on Food Contact Materials. This is the first major overhaul since 2016 and marks a significant step forward in aligning ink manufacturing practices with modern quality systems, global production realities, and updated regulatory expectations. For converters, suppliers and packaging producers, the new GMP offers a clearer, more structured framework to help ensure safety and compliance across the entire ink supply chain.
Table of Contents
A New Structure for a Changing Industry
The most visible update in the 5th revision is the complete restructuring of the GMP. EuPIA has aligned the document with ISO 9001:2015, giving manufacturers a quality-management layout they already know and use. This simplifies integration into existing systems and improves day-to-day usability.
The updated structure also reflects how the packaging industry has evolved. Ink production is no longer confined to Europe alone. Many EuPIA member companies now also operate global facilities, and the previous region-limited approach no longer matches reality. The revised GMP expands its geographical scope so companies can apply it consistently across all their operations.
Clearer Roles: The “Competent Person”
One of the standout additions is the definition of the “competent person.” Earlier versions implied the need for such a role, but version 5 makes it explicit and describes the knowledge and training required. This includes regulatory awareness, raw-material selection, NIAS and NLS assessment skills, migration interpretation, hygiene practices and internal procedures.
For manufacturers, this means responsibility is no longer vague, and for customers, it provides confidence that qualified individuals oversee safety-critical decisions.
Stronger Links to EuPIA Guidance
The new GMP creates a tighter, more practical network of references to other EuPIA documents. It also highlights tools that many ink manufacturers are already using but had not been formally tied into the GMP framework. These include:
- Migration testing guidance
- NIAS and NLS risk assessment guidelines
- Suitability lists for photoinitiators and photosynergists
- General risk-assessment and raw-material selection guidance
This interlinking ensures that any company applying the GMP also uses the right supporting documents and avoids gaps that could cause compliance issues downstream later.
Raw Materials: More Transparency, Less Uncertainty
EuPIA has added clarity on what information manufacturers should expect regarding raw-material composition. This includes what NIAS a raw material may reasonably be expected to contain and what impurities are typical based on the chemistry involved. These expectations strengthen the risk-assessment process and help avoid the trial-and-error approach that previously occurred when suppliers failed to provide sufficient details.
FMEA and HACCP: Reinforced Risk Management
Food-contact safety depends heavily on anticipating and mitigating hazards. The revised GMP underlines the aforementioned by embedding Failure Modes and Effects Analysis (FMEA) as the standard method for risk assessment. It also incorporates HACCP principles more explicitly, creating a consistent way to evaluate chemical, microbiological and physical risks.
New or updated elements include:
- Defined intervals for reviewing risk assessments
- A stronger link between change management and risk reassessment
- Clearer guidance on worst-case calculations
- Enhanced focus on cross-contamination prevention, especially for DFC (Direct Food Contact) inks
This brings the ink sector closer to the food industry’s own safety approach, which is essential as packaging becomes more complex and regulatory scrutiny increases.
Expanded Operational Requirements
The revised document strengthens expectations across operations, including:
- Hygiene and infrastructure: More detailed zoning and cleanliness requirements, supported by examples and risk-based decision making.
- Equipment and maintenance: Explicit expectations for validated cleaning procedures, particularly where equipment is shared between FCM and non-FCM inks.
- Cleaning agents and auxiliary materials: Stricter control on approval, segregation and worst-case migration calculations for any chemical that could remain as residue.
- Packaging and labelling: Requirements for virgin or validated containers for DFC inks, improved cleanliness inspections and clearer labelling.
- Customer communication: Expanded rules on technical data sheets, statements of composition, migration-related information and application suitability.
- Traceability: A more robust pathway both forward and backward, with mandatory testing of traceability systems.
Why This Matters for the Packaging Supply Chain
The revised GMP reflects the rising expectations throughout the food packaging value chain. Retailers, brand owners, converters and regulators all demand more transparency, better documentation and higher safety assurance. At the same time, converters gain clearer information on ink suitability, enabling more reliable compliance assessments for finished food-contact materials.
Conclusion
EuPIA’s 5th revised GMP is a major redesign that brings ink-manufacturing practices in line with modern quality systems and the complex reality of global supply chains. With clearer rules, stronger risk-management requirements and better integration with EuPIA’s supporting guidance, the new GMP sets a higher and more consistent standard for inks used on food-contact materials.
EuPIA members are expected to introduce and apply the new GMP from 1 January 2026.
You can find the revised 5th version of the GMP here.
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