Three Practical Boundaries of Swiss LFGB and German BfR Requirements: Inks and Coatings for Food-Contact Paper—Which Three Documents Should Printers Request First for DACH Orders
💡 💡 At a Glance
Three practical boundaries govern food-contact packaging compliance in the DACH region. First, Switzerland and Germany do not use one set of documents: Switzerland applies federal ordinance SR 817.023, while Germany applies the LFGB federal law plus state-level provisions, with assessments based on BfR recommendation numbers. The permitted conditions for the same ink may differ between the two markets, so a Swiss review cannot be reused directly for Germany. Second, a paper compliance declaration does not cover the ink. Printing ink is independently regulated as a Bedruckstoff, and white undercoats, functional coatings, and hot foil layers in areas that may contact food require separate assessment. A paper certificate combined with an ink MSDS is a typical package that will not pass the customer's review. Third, three criteria have no numerical standards: no wet color transfer, no bleed-through, and no aroma transfer. Paper-based packaging generally does not undergo overall migration testing, so compliance must be demonstrated through process parameters rather than a test report. When accepting DACH orders, printers should first request three documents: the ink supplier's declaration referencing the specific applicable BfR recommendation number, the customer's written description of the intended use, including food type, duration, temperature, and heating conditions, and the customer's own signed declaration of conformity. The printer provides supporting evidence, not the final signature.
In September 2026, a Swiss customer producing oat clusters sent us an inquiry with only one sentence in the attachment: “Please provide the compliance declaration for the printed food contact material.”
We replied with a standard email attaching three documents: our factory's ISO 9001 certificate, the MSDS for the food-grade soybean ink we use, and a third-party test report from our previous export order showing migration results, issued by SGS.
The customer replied the next day in German. Translated, it said: “This is proof of the substrate, not of the printing material.”
Then came a third message: “We do not need your certificates. We need a declaration that the printing ink complies with Article 23 of SR 817.023, and the declaration must identify the BfR recommendation on which it is based.”
We did not accept that order. It was not because the job was technically impossible. We had simply failed to understand the legal position of the products we were selling.
Food-contact packaging compliance in the DACH region follows a different logic from the familiar notion that exports to Europe and North America require FDA and REACH documentation. It does not end with CE marking, a test report, or even the printer's own declaration. It is a declaration signed by “the party responsible for the use,” while the printer's role in this chain is to provide evidence and carry out the printing process.
The First Boundary: Switzerland and Germany Do Not Use One Set of Documents
This is the point where printers are most likely to make an unjustified assumption. Hearing “DACH region,” they assume that Switzerland, Germany, and Austria follow the same rules and use one set of documents for all three markets.
In reality, Switzerland's rules for food-contact materials are set out in the federal ordinance SR 817.023, which applies to the entire industry, and customers require a declaration demonstrating compliance with that ordinance. Germany's system works differently. At the federal level, compliance is governed by the LFGB (Food, Consumer Products and Feed Act), while the specific assessment of food-contact materials relies on numbered “recommendations” issued by the BfR (Federal Institute for Risk Assessment), known as BfR Empfehlung. Each recommendation identifies the recommended quantities and conditions for using a particular substance in food-contact applications.
Germany also has a level that Switzerland does not: individual states have their own local LFGB provisions. Although these provisions do not override federal requirements, registration and filing obligations for certain product categories, such as children's products and disposable tableware, may differ.
As a result, an order may require different documents depending on its destination. For the same cardboard and the same ink, a shipment to Switzerland must comply with SR 817.023 and its annexes; a shipment to Germany requires a line-by-line review of the applicable BfR recommendation numbers and conditions; and an Austrian order may involve yet another formulation of national requirements.
Customers typically say: “Our recipe and our packaging have to comply with the Swiss Ordinance. For Germany we need the BfR recommendation reference on the ink declaration.”
Our factory divides Switzerland, Germany, and Austria into three columns. The documents may not all be different, but the internal checklist used for verification is different for each market. For Switzerland, we check the ordinance's annexes and lists of prohibited and restricted substances. For Germany, we check the BfR recommendation numbers and their conditions of use. For Austria, we additionally determine whether the relevant state-level provisions impose any extra requirements on top of the German requirements. We review each of the four material categories separately: paper, ink, coating, and adhesive.
When customers ask, “Can you handle Switzerland only?” the answer is yes. However, once they add, “Send some to Germany as well,” the Swiss review cannot be reused directly, because a significant number of substances covered by BfR recommendations are either absent from the Swiss ordinance or subject to different conditions. The reverse is also true: the Swiss ordinance prohibits certain substances that remain permissible under BfR recommendations. Printers must investigate these differences themselves rather than relying on customers to do it.
The Second Boundary: A Paper Compliance Declaration Does Not Cover the Ink
This was the most immediate cause of our failure and is also the issue most frequently raised during DACH customer audits.
In the regulatory context of the DACH region, printing ink is an independently regulated subject, not merely part of the substrate on which it is printed. The regulations assign this material a specific designation: the German term is Bedruckstoff, literally “printing substance.” It is also listed as a separate category under the Swiss ordinance. It has its own list of permitted substances, restrictions, and assessment methodology.
This creates an awkward scenario: the customer receives our documents, only to find that they prove from beginning to end that “this cardboard may come into contact with food,” while the ink layer—the layer most likely to migrate into the food—remains unaddressed.
We remembered the customer's words for a long time: “Your paper certificate is valid, but the ink is the layer that touches my product. Where is your ink declaration?”
Many printers assume that only black, red, and gold inks need to be considered. In reality:
First, every printing layer on the food-contact surface must be assessed. Even white ink used as an undercoat is an ink and requires a declaration. In many orders, customers are particularly concerned about white ink because it is the first layer printed directly onto food-contact paper.
Second, functional additives in coatings require review. Water resistance, oil resistance, and abrasion resistance may appear to be finishing processes, but if a coating is intended to perform a function under food-contact conditions, such as moisture resistance or barrier performance, it is regulated as a food-contact material. Interestingly, coatings that qualify as functional must be assessed according to food-contact requirements, while purely decorative protection, such as scratch resistance or protection against water and dirt, may be treated as indirect contact when separated from the food-contact surface by a barrier.
Third, finishing processes such as hot foil stamping, UV curing, and desiccant insertion also require attention. Hot foil stamping is controversial in DACH food-contact packaging. The general principle is that the foil layer does not directly contact food; however, if the foil-printed area could contact food—for example, a foil design on an inner liner—it must be assessed as an ink.
We subsequently changed our procedure. At the quotation stage, we request declarations from suppliers for three layers: “materials + printing layers + finishing processes.”
The Third Boundary: Assessments Without Numerical Standards
The third boundary is easiest to overlook because it does not take the form of a certificate. Instead, it appears as a collection of conditions that “look compliant but cannot be proven.”
Food-contact plastics are subject to the overall migration limit under EU 10/2011. Because the standard contains numerical values, testing laboratories can issue a clear “pass/fail” conclusion. Paper-based packaging is different. Paper boxes generally do not undergo overall migration testing in the EU or Switzerland because paper is a complex mixture of natural fibers, and the methodology for overall migration testing is not sufficiently robust.
What, then, governs paper-based packaging? It relies on three qualitative but actionable criteria, generally described in the DACH region as follows:
First, no color transfer under wet abrasion. Paper can lose color when exposed to moisture, making this the most typical failure mode for paper-based packaging. The test usually simulates wet abrasion by repeatedly rubbing the printed surface with a damp cloth or finger and then checking whether any color transfers onto white paper. This criterion has a relatively clear pass standard: no transfer to white paper is permitted.
Second, bleed-through. Soluble components of the ink can pass through the paper and appear on the reverse side, particularly under stacking pressure or in high-temperature, high-humidity conditions. This issue is generally addressed through the barrier performance of the paper and coating.
Third, aroma transfer. Residual solvents in solvent-based inks can pass through cardboard and transfer an odor to the product. Customers pay particularly close attention to this risk for coffee, tea, nuts, and similar products.
The key point is that none of these three criteria provides a numerical pass value. They involve relative comparisons and sensory assessment. Printers therefore cannot obtain a permanent certificate of compliance through testing alone. They must control the process: select an appropriate ink system, prioritizing water-based or soybean inks for food-contact use instead of general-purpose solvent inks; control drying, including residual solvent levels and curing; and add a barrier coating where necessary.
A customer once said, “Send me the test report.” We replied: “A report can demonstrate that component levels are not exceeded, but it cannot prove that your coffee will still be odor-free after three months. These three matters depend on process control.”
This is the part that actually needs to be discussed. Customers are not asking for a piece of paper. They want proof of what you did.
Which Three Documents Should Printers Request First for DACH Orders?
Bringing the three boundaries together produces three operational questions and three corresponding documents.
First: the ink supplier's declaration of conformity referencing the specific applicable BfR recommendation number. The critical phrase is “specific number.” We do not ask the ink supplier for a general statement that the ink “meets food-contact requirements.” Instead, the declaration must identify the applicable BfR recommendation numbers, the conditions of use, including the type of food, temperature, and duration of contact, and any specific usage limits. This document normally has to be obtained from the ink supplier's regulatory affairs department rather than its sales team.
The customer typically asks: “Which BfR recommendation number applies to your ink?”
Second: the customer's written description of the intended use. This requirement is both the easiest to overlook and the most critical. BfR recommendations contain conditions of use. The same ink may have completely different conditions when used with dry cereals and oily foods, and different requirements may apply to short-term contact at 23°C and heating at 90°C.
We therefore ask the customer to specify three matters in writing: the food category to be contacted, including dry, aqueous, oily, alcoholic, or high-acid/high-salt products; the duration and temperature of contact; and whether the packaging will be heated or microwaved.
If the customer cannot provide this information, we do not guess on their behalf. An incorrect assumption means that the printed packaging is used outside the declared conditions. Responsibility would formally rest with the customer, but the customer would likely come back to the printer when problems arise.
Third: the customer's own signed declaration of conformity. This is the most critical and most counterintuitive document. Under the applicable rules, the final declaration of conformity is signed by the party placing the packaging on the market and determining its intended use, not by the printer. The printer's role is to provide the technical evidence needed to support the customer's declaration.
One customer said, “You sign it, and we just forward it.” We replied: “The signatures are yours. We provide three things: the ink declaration, the technical confirmation of the intended use, and our process parameter records. Together, these form the supporting evidence for your declaration.”
Our factory's current standard practice is to package these three items as a “Printing-Layer Compliance Support Pack.” The file name clearly states that it contains “supporting materials,” not a “declaration of conformity.” This distinction is not mere pedantry: it determines our position in the chain of responsibility if a problem occurs.
One Sentence for Customers
The most counterintuitive aspect of DACH compliance is that customers do not want “your certificate”; they want to know “which provision your declaration is based on.”
Certificates can be copied and reused, but the basis for a declaration cannot. We have therefore changed how we communicate with customers. Instead of sending a stack of PDF files, we map each material to a specific numbered provision in a comparison table showing the material name, supplier, applicable ordinance or BfR number, conditions of use, and traceability information for the corresponding batch.
We often tell customers: “Define the intended use first, then discuss the materials.” Intended use is the master switch. Once it changes, the suitability of the paper, ink, and coating must all be reassessed. Purchasing materials before establishing the intended use reverses the correct sequence and will inevitably lead to rework.
Further Reading
- What Is FDA Food-Contact Material Certification? A Practical Guide to 21 CFR for Exports to the United States—the U.S. framework follows a different logic from that of the DACH region
- EU REACH Certification for Packaging Materials: How to Check the SVHC List—how EU-level chemical lists interact with national food-contact rules
- Three Hidden Compliance Requirements for Food Packaging Exports to Japan: Japanese Labels, JAS Organic, and the Food Sanitation Act—another market where a generic certificate is not enough
- Six Mandatory Food Packaging Labels: Ingredients, Allergens, Shelf Life, Nutrition Facts, Net Weight, and Country of Origin—label compliance and material compliance follow two separate systems on the same package
FAQ
Do printers need two entirely different sets of documents for food-contact packaging compliance in Switzerland and Germany?
Not two entirely different sets, but two different verification checklists. Switzerland applies federal ordinance SR 817.023 and the prohibited and restricted substance lists in its annexes, and customers require a declaration demonstrating compliance with that ordinance. Germany applies the federal LFGB plus state-level local provisions, with assessments based primarily on numbered BfR recommendations and their conditions of use. The materials themselves are often the same; the difference lies in the specific regulatory entries that must be checked and the numbers cited in the declaration. If an order includes both Switzerland and Germany, we internally review it in three columns—Switzerland, Germany, and Austria—rather than using the Swiss review directly for Germany.
If the customer only requests a food-contact certificate for the paper, does the ink still require a separate declaration?
Yes. DACH regulations treat printing ink, known in German as Bedruckstoff, as an independently regulated subject rather than part of the substrate. A paper compliance declaration proves only that the paper itself may contact food, while the ink printed on it is the layer most likely to migrate into the contents. White ink undercoats also count as ink. Although many printers believe only black, red, and gold inks are relevant, functional coatings for moisture and barrier performance, as well as hot foil layers in areas that may contact food, must be assessed separately. At the quotation stage, our factory requests declarations for three layers—materials, printing layers, and finishing processes—rather than asking only whether generic food-contact evidence exists.
How can printers demonstrate compliance with the three non-numerical criteria of no wet color transfer, no bleed-through, and no aroma transfer?
Through process parameter records rather than a single report. Paper-based packaging generally does not undergo overall migration testing in the EU or Switzerland and is assessed primarily through qualitative criteria: no transfer to white paper after wet abrasion, no penetration of soluble ink components through the paper to the reverse side, especially under stacking pressure and high-temperature, high-humidity conditions, and no transfer of solvent residues through cardboard to the contents. Because none of these criteria has a numerical pass value, testing laboratories may be unable to issue a definitive pass/fail conclusion. Printers can instead demonstrate the ink system selected, preferring water-based or soybean inks rather than general-purpose solvent inks for food contact; the drying and curing conditions applied; and whether a barrier coating was added. These parameters should be recorded and retained by batch so they can be presented when requested by customers or auditors.
If a customer says, “Just sign the declaration of conformity and send it to us,” can the printer sign it?
The printer should not sign the final declaration. Under DACH rules, the final declaration of conformity is signed by the party placing the packaging on the market and determining its intended use, which is not the printer. The printer can provide three supporting items: the ink supplier's declaration of conformity referencing the specific applicable BfR recommendation number, the customer's written confirmation of the intended use, and the printer's process parameters and batch records. When these are compiled, the file name should deliberately describe them as “supporting materials” or a “basis-of-compliance list,” not a “declaration of conformity.” This clear distinction keeps the printer in the role of evidence provider rather than signatory if an incident occurs.
What should a printer do if the customer cannot provide the intended use, including the food type, contact duration, and temperature?
Do not guess, but explain why the information must be defined. BfR recommendations contain conditions of use. The same ink may be subject to entirely different conditions for dry cereals, oily foods, and alcoholic beverages, while increasing the contact temperature from short-term use at room temperature to heating at 90°C changes the requirements again. Intended use is the master switch; once it changes, the suitability of the paper, ink, and coating must be reassessed. The practical solution is to provide the customer with a simple selection form covering food categories, such as dry, aqueous, oily, alcoholic, or high-acid/high-salt products; conditions such as room temperature, heating, or microwaving; and contact duration. The printer should also explain that responsibility for any use exceeding the scope of the declaration rests with the customer, who will likely return to the printer if packaging-related taste or odor issues arise.
For the same ink supplied to Swiss and German customers, must printers request different documents from the ink supplier?
Yes, because the regulatory references differ. For Swiss customers, we request a compliance statement from the ink supplier referencing SR 817.023 and its annexes. For German customers, we request a declaration referencing the specific applicable BfR recommendation number. A different number may mean different restrictions and usage limits. In practice, these documents should be requested from the ink supplier's regulatory affairs department rather than its sales team, because sales representatives generally provide only a general statement that the ink meets food-contact requirements. The table containing the material name, reference number, and conditions of use should accompany each batch as one of the strongest deliverables during an audit.
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